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

           BACKGROUND DOCUMENT FOR

        K046 NONREACTIVE  SUBCATEGORY
           James  R.  Berlow, Chief
        Treatment Technology Section
             Juan  Baez-Martinez
               Project Manager
    U.S.  Environmental  Protection Agency
            Office of Solid Waste
             401  M  Street,  S.W.
           Washington,  D.C.  20460
                 August 1988

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                             TABLE OF CONTENTS



Section                                                              Page

EXECUTIVE SUMMARY 	            vii

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 Groups 	            1-7
          1.2.2   Demonstrated and Available Treatment
                  Technologies 	            1-7
          1.2.3   Collection of Performance Data 	            1-11
          1.2.4   Hazardous Constituents Considered and
                  Selected for Regulation 	            1-17
          1.2.5   Compliance with Performance Standards...            1-30
          1.2.6   Identification of BOAT 	            1-32
          1.2.7   BOAT Treatment Standards for "Derived-
                  From" and "Mixed" Wastes 	            1-36
          1.2.8   Transfer of Treatment Standards 	            1-40
     1.3  Variance from the BOAT Treatment Standard	            1-41

2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION	            2-1

     2.1  Industry Affected and Process Description 	            2-1
     2.2  Waste Characterization	            2-8

3.   APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES	            3-1

     3.1  Applicable Treatment Technologies 	            3-1
     3.2  Demonstrated Treatment Technologies 	            3-2
     3.3  Detailed Description of Treatment Technologies..            3-3
          3.3.1   Stabilization of Metals 	            3-3

4.   PERFORMANCE DATA BASE 	            4-1

5.   IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE
     TECHNOLOGY (BOAT) for K046	            5-1

     5.1  Review of Performance Data 	            5-2
     5.2  Accuracy Correction of Performance Data 	            5-3
     5.3  Statistical Comparison of Performance Data 	            5-6
     5.4  BOAT for K046 Waste 	            5-7

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                       TABLE OF CONTENTS (Continued)
Section

6.    SELECTION OF REGULATED CONSTITUENTS 	

7.    CALCULATION OF BOAT TREATMENT STANDARDS 	

     7.1  Editing the Data 	
     7.2  Correcting the Remaining Data 	
     7.3  Calculating the Variability Factors 	
     7.4  Calculating the Treatment Standards 	

8.    ACKNOWLEDGMENTS  	

9.    REFERENCES  	




APPENDIX A   Statistical Methods 	

APPENDIX B   Analytical  QA/QC 	

APPENDIX C   Detection Limits for Untreated and Treated
             K046 Wastes 	

APPENDIX D   Calculation of Treatment Standards	

APPENDIX E   Determination of Nonreactive and Reactive
             Forms of K046 	
Page

6-1

7-1

7-1
7-2
7-3
7-5

8-1

9-1
A-l

B-l


C-l

D-l


E-l

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                               LIST  OF  TABLES

Table                                                                Page

1-1  BOAT CONSTITUENT LIST 	            1-18

2-1  FACILITIES PRODUCING K046 BY STATE 	            2-3

2-2  FACILITIES PRODUCING K046 BY EPA REGION 	            2-4

2-3  MAJOR CONSTITUENT COMPOSITION FOR K046 WASTE 	            2-9

2-4  BOAT CONSTITUENT COMPOSITION AND OTHER DATA 	            2-10

4-1  TREATMENT DATA FOR K046 STABILIZATION USING
     PORTLAND CEMENT 	            4-2

4-2  TREATMENT DATA FOR K046 STABILIZATION USING KILN
     DUST 	            4-3

4-3  TREATMENT DATA FOR K046 STABILIZATION USING
     LIME/FLVASH 	            4-4

5-1  TREATMENT DATA USED FOR REGULATION OF K046 WASTE ...            5-4

5-2  K046 NONWASTEWATER DATA SHOWING SUBSTANTIAL
     TREATMENT BY CEMENT STABILIZATION  	            5-8

6-1  BOAT LIST METALS DETECTED IN UNTREATED
     WASTE 	            6-2

7-1  REGULATED CONSTITUENTS AND CALCULATED TREATMENT
     STANDARDS FOR K046 NONWASTEWATERS 	            7-4

A-l  95TH PERCENTILE VALUES FOR THE F DISTRIBUTION	            A-2

B-l  ANALYTICAL METHODS 	            B-2

B-2  SPECIFIC PROCEDURES OR EQUIPMENT USED IN PREPARATION
     AND ANALYSIS OF METALS WHEN ALTERNATIVES OR EQUIVA-
     LENTS ARE ALLOWED IN THE SW-846 METHODS 	           B-3

B-3  MATRIX SPIKE FOR METALS FOR THE TCLP EXTRACT FOR THE
     CEMENT BINDER K046 	           B-4
                                     IV

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                        LIST OF TABLES  (Continued)

Table                                                                Page

B-4  MATRIX SPIKE FOR METALS FOR THE TCLP EXTRACT FOR THE
     KILN DUST K046 	           B-5

B-5  MATRIX SPIKE FOR METALS FOR THE TCLP EXTRACT FOR THE
     FLY ASH BINDER K046 	           B-6

C-1  DETECTION LIMITS FOR UNTREATED K046 	           C-2

C-2  DETECTION LIMITS FOR TREATED K046 	           C-3

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                              LIST OF FIGURES
Figure                                                               Page

2-1  FACILITIES PRODUCING K046 BY STATE AND EPA
     REGION 	            2-5

2-2  LEAD AZIDE MANUFACTURE 	            2-6
                                     VI

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                             EXECUTIVE SUMMARY
                     BOAT Treatment Standards for K046
    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 261.31' as K046.  Compliance with these BOAT treatment standards is
a prerequisite for placement of the waste in units designated as land
disposal units according to 40 CFR Part 268.  The effective date of these
treatment standards is August 8, 1988.
    In promulgating treatment standards for K046 nonwastewaters, the
Agency has established two subcategories:  Nonreactive Subcategory and
Reactive Subcategory.   For a protocol to determine whether a
nonwastewater form of K046 is Nonreactive or Reactive, see Appendix E.
In this background document, the promulgated treatment standards apply to
the Nonreactive Subcategory of the K046 nonwastewaters.  Treatment
standards for the Reactive Subcategory of K046 nonwastewaters will be
established by the Agency at a later date.  Until these treatment
standards are established, K046 nonwastewaters in the Reactive
Subcategory are restricted from land disposal according to the  "soft
hammer" provisions, as stated in the Preamble for this rule, Section  III
(c) 3.

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    This background document provides the Agency's rationale and
technical support for selecting the constituents to be regulated in the
K046 waste and for developing treatment standards for those regulated
constituents.  The document also provides waste characterization
information that serves as the basis for determining whether variances
may be warranted for a particular waste that has the same waste code but
has waste characteristics that make it more difficult to treat than the
waste upon which the BOAT treatment standards are based.
    The introductory section, which appears verbatim in all the First
Third background documents, summarizes the Agency's legal authority and
promulgated methodology for establishing treatment standards and
discusses the petition process necessary for requesting a variance from
the treatment standards.  The remainder of the documents presents
waste-specific information  the number and locations of facilities
affected by the land disposal restrictions for the K046 waste, the
waste-generating process, characterization data, the technologies used to
treat the waste (or similar wastes), and available performance data,
including data on which the treatment standards are based.  The document
also explains EPA's determination of BOAT, selection of constituents to
be regulated, and calculation of treatment standards.
    According to 40 CFR 261.32, waste code K046, which  is generated by
the explosives industries, is listed as follows:
    K046:  Wastewater treatment sludges from the manufacturing,
           formulation, and loading of lead-based initiating compounds.

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    EPA has estimated that 62 facilities in the explosives industry are

potential generators of the K046 waste.  Generators of K046 waste

generally fall under Standard Industrial Classification (SIC) Code 2892

(explosives).

    Treatment standards are established for nonwastewater forms of K046.

(For the purpose of determining the applicability of the treatment

standards, wastewaters are defined as wastes containing less than

1  percent (weight basis) total suspended solids* and less than 1 percent

(weight basis) total organic carbon (TOC).  Waste not meeting this

definition must comply with the treatment standards for nonwastewaters.)

    For K046 nonwastewater, the Agency is establishing a treatment

standard for lead.  The treatment standard is based on performance data

from stabilization using a portland cement binder.  The Agency has not

collected performance data for wastewater forms of K046, and treatment

standards for K046 wastewaters were not established.  As a result, K046

wastewaters are restricted from land disposal according to the "soft

hammer" provisions, as stated in the Preamble, for this rule, Section III

(c) 3.
*   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 103-105C) in Standard Methods
    for the Examination of Water and Wastewater, 16th edition.

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    The following table presents the treatment standard for K046 waste.
The treatment standard for K046 nonwastewaters reflects the concentration
of constituents in the leachate from the Toxicity Characteristic Leaching
Procedure (TCLP) and the units are mg/1 (parts per million on a
weight-by-volume basis).  If the concentration of the regulated
constituent in K046 waste, as generated, is lower than or equal to the
proposed BOAT treatment standard, then treatment is not necessary as a
prerequisite to land disposal.
    Testing procedures are specifically identified in Appendix B of this
background document.

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                     BOAT Treatment Standards for K046
                          Nonreactive Subcategory
                           Maximum for any single grab sample
                  	Nonwastewater	        Wastewater3
                       Total         TCLP leachate           Total
                  concentration      concentration       concentration
Constituent           (fig/kg)           (mg/1)               (mg/1)


Lead                    NA               0.18
NA = Not applicable.

aEPA intends to propose and promulgate numerical treatment standards
 for K046 wastewaters prior to May 8, 1990.
                                     XI

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                              1.   INTRODUCTION
    This section of the background document presents a summary of the
logal 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
:>urface 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 BDAT 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 visits strictly on the basis of which



facility could most expeditiously be visited and later sampled if



justified by the engineering visit.



    (2)  Engineering site visit.  Once a treatment facility has been



selected, an engineering site visit is made to confirm that a candidate



for sampling meets EPA's criteria for a well-designed  facility and to
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ensure that the necessary sampling points can be accessed to determine



operating parameters and treatment effectiveness.  During the visit, EPA



also confirms that the facility appears to be well operated, although the



actual operation of the treatment system during sampling is the basis for



EPA's decisions regarding proper operation of the treatment unit.   In



general, the Agency considers a well-designed'facility to be one that



contains the unit operations necessary to treat the various hazardous



constituents of the waste, as well as to control other nonhazardous



materials in the waste that may affect treatment performance.



    In addition to ensuring that a system is reasonably well designed,



the engineering visit examines whether the facility has a way to measure



the operating parameters that affect performance of the treatment system



during the waste treatment period.  For example, EPA may choose not to



sample a treatment system that operates in a continuous mode, for which



an important operating parameter cannot be continuously recorded.   In



such systems, instrumentation is important in determining whether the



treatment system is operating at design values .during the waste treatment



period.



    (3)  Sampling and analysis plan.  If after the engineering site visit



the Agency decides to sample a particular plant, the Agency will then



develop a site-specific sampling and analysis plan (SAP) according  to the



Generic Quality Assurance Pro.lect Plan for the Land Disposal Restrictions



Program ("BOAT"). EPA/530-SW-87-011.  In brief, the SAP discusses where



the Agency plans to sample, how the samples will be taken, the frequency
                                    1-14

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

-------
    (Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA.  Such facilities
should review the Generic Quality Assurance Pro.iect Plan for the Land
Disposal Restrictions Program ("BOAT"), which delineates all of the
quality 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   BDAI Constituent list
BOAT
reference
no.

222.
\ .
2.
3.
4.
5.
6.
223.
/.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
IB.
19.
20.
21.
22.
23.
24.
25.
26.
2;.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
2X8.
34.
Constituent
Volat i le organ ics
Acetone
Acetonitri le
Aero le in
Acrylonitri le
Benzene
Bromod ich loromcthdnc
Bromomethane
n-Butyl alcohol
Carbon letrachloride
Carbon disu If ide
Ch lorobenzene
2-Chloro-l,3-butadiene
Ch lorod ibromome thane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Ch loropropene
1.2-0 ibromo-3-ch loropropane
1.2-Dibromoethane
D ibromome thane
trans-1 ,4-Oichloro-2-butenc
Dich lorod if luoromethane
1. 1-Dichloroethane
1 ,2-Dichloroethane
1 . 1 -0 ich loroethy lenc
trans-1 .2-Dichloroethene
1 ,2-Dichloropropane
trans-1 ,3-Dich loropropunu
cis-l,3-0ich loropropene
1 , 4-Oioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl ben/ene
Ethyl cyanide
Cthyl ether
Ethyl melhdcry lale
Ethylene oxide
lodome thane
Isobutyl alcohol
Mothano 1
Mclhyl ethyl kutonc
CAS no.

6/-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110 75 8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71 8
75-34-3
107-06-2
75-35-4
156-60-5
/8-B/-5
10061-02-b
10061-01-5
123-91-1
110-80-5
141-/8-6
100-41-4
107-12-0
60-29-/
97-63-2
75-21 8
74 88 4
78-83-1
6/-!li-l
78 93 3
                                   1-18

-------
IbZlg
                         lable  1-1  (Conlinued)
UDAI
reference
no.

229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
4B.
49.
231.

50.
215.
?16.
217.

51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
G3.
64.
65.
66.
Constituent
Volati le orqanics (continued)
Methyl isobutyl ketone
Methyl met hacry late
Methacrylonilri le
Methylene chloride
2-Nitropropane
Pyridine
1,1. 1.2-Ietrachloroethane
1 . 1 ,2.2-Ietrachloroethane
Tetrach loroethenc
Toluene
Tnbromome thane
1,1. 1-lrichloroethdne
1 . l.?-Trichloroethane
Trichloroethene
Tr ichloromonof luoromethane
1 . 2.3- fr ich loropropanu
1. 1.2-Trichloro- 1.2.2- tr if luoro-
ethane
Vinyl chloride
1,2-Xylene
1.3-Xylcne
1.4 Xylene
Semivolatile orqanics
Acenaphtha lene
Acenaphthene
Acelophenone
2-Acety laminof luorenc
4-Aminobipheny 1
Ani line
Anthracene
Aramite
Benz ( a ) an t hracene
Benzal chloride
Bunienethio 1
Deleted
Benzo(a)pyrene
Benzo( b ) f luoranthene
Bc;fi/o(yhi )pery lene
Ben^o(k)f luoranthcno
p Benzoquinone
CAS no.

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

/5-01-4
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
108-9H-5

50-32-8
205-99-2
191-?4 ?
?07-08-'J
106 51-4
                                   1-19

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

67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
II .
78.
79.
80.
81.
8?.
232.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
101.
IDS.
106.
219.
Const ituent
Semi volatile organ ics (continued)
B is( 2 -chloroethoxy (methane
Bis(2-chloroethyl)ether
B is(2-ch loro isopropy 1 ) ether
Bis(?-ethy Ihcxy 1 (phtha late
4 Bromophenyl phenyl ether
Butyl benzyl phtha late
2-sec-Buty 1-4.6-dmttropheno 1
p-Ch loroani 1 ine
Chlorobenzi lute
p-Chloro-m-cresol
2-Ch loronaphtha lene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Crcsol
Cyc lohexanone
D i benz( a. h) anthracene
Oibenzo(a,e)pyrene
Dibenzo(a, ijpyrene
m- D ich lorobenzene
o - D ich lorobenzene
p-D ich lorobenzene
3, 3 '-D ich lorobcn/ id ine
2 . 4-0 ich loropheno 1
2.6-Dichlorophenol
Oiethyl phthalale
3,3'-Dimethoxybenz idinc
p Oimethylaminoazobenzene
3,3'-Dimethylbenzidme
2.4-Dimethy Iphenol
Dimethyl phthalale
Di-n-butyl phthalate
1.4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitropheno 1
2,4-Oinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phtha late
l)i-n-propy In i tros.immt:
Dipheny lam me
Dipheny Ini trosamine
CAS no.

111-91 1
111-44-4
39638-32-9
117-81-7
101 55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76 7
218-01-9
95-48-7
106-44-5
108-94 1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120 83 2
87-65-0
84-66-2
119-90-4
60 11-7
119-93-7
105 137-9
131-11-3
84-74-2
100-25-4
534-52-1
51-28-5
121-14 2
606-20-2
11/-B4-0
621-li4-7
122 39 4
86-30-6
                                   1-20

-------
I521g
                         Table 1-1  (Continued)
BUAI
reference
no.

107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
ll/.
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.
Const ituent
Semivo lat i le orcidn ics (continued)
1 . 2-Diphenylhydrarine
F luoranthene
F luorene
Hexach lorobcn/ene
Hexach lorobutad iene
Hexachlorocyclopentadiene
Hexach loroetham*
Hexach lorophene
Hexach loropropene
1 ndeno ( 1 . 2 . 3 -cd ) py rene
Isosafrole
Methapyri lene
3-Hethylcholanthrene
4.4'-Methy lenebis
(2-chloroani 1 ine)
Methyl met hancsul fondle
Naphtha lene
1 . 4 -Naphthoqu inone
1 -Naphthy lamme
2-Naphthy lamine
p-Nitroani line
Nitrobenzene
4-Nitrophenol
N-Nitrosodi -n-butylamine
N-N itrosodiethy lamine
N-N itrosodimethy lamine
N-N i trosomethy le thy lam me
N-N itrosoraorpho 1 ine
N-Nitrosopiper idine
N-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pentach lorobcn/ene
Pentachloroethane
Pentach loron i t robenzene
Pen tdch lorophcno 1
Phenacetin
Phenanthrene
Phenol
Phtha 1 ic anhydride
2-Picol ine
Pronamide
Pyrene
Hesorcino 1
CAS no.

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

101-14-4
66-27-3
91-20-3
130-15-4
134-32-7
91-59-8
100-01-6
98-95-3
100-02-7
924-16-3
55-18-5
62-75-9
10595-95-6
59-89-2
100-75 4
930-55-2
99-65-8
608 93 5
76-01-7
82-68-8
87-86-5
62-44-?
85-01-8
108-95-2
85-44-9
109-06-8
23950 58 5
129-00-0
10H-46-3
                                   1-21

-------
1521q
                        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.
16/.
168.

169.
170.
1/1.

172.
1/3.
174.
175.
Constituent
Semivolat i le ornanics (continued)
Safrole
1 . 2,4.5- letrdchloroben/une
2.3,4. 6- Tet rach lorophcno 1
1.2,4-Trichlorobenzene
2.4,5-Trichlorophenol
2 , 4 . 6- T r ich lorophcno 1
Tris(2.3-dibromopropy 1 )
phosphate
Metals
Ant imony
Arsenic
Barium
Beryl ) ium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thai lium
Vanadium
Zinc
Inorganics other than metals
Cyanide
fluoride
Sulfide
Orqanochlorine pesticides
Aldrin
d Ipha-BHC
beta-BHC
delta-BHC
CAS no.

94-!j9-/
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2

126-72-7

7440-36 0
/440-38-2
/440-39-3
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
/440-62-2
7440-66-6

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

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

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

176.
177.
178.
179.
ISO.
181.
182.
1B3.
184.
185.
186.
187.
188.
189.
190.
191.

192.
193.
194.

195.
196.
197.
198.
199.

200.
201.
202.
203.
204.
205.
206.
Constituent
Orqanochlorine pesticides (continued)
g
-------
1521g
                           lable  1-1   (Continued)
BOAT
reference      Constituent                               CAS  no.
no.	

               Dioxins and furans

?07.           Hexachlorodibcnzo-p-dioxins
208.           Hexachlorodibenzofurans
209.           Pentachlorodibenzo-p-dioxins
210.           Pentacnlorodiben/ofurans
211.           Tetrachlorodibcnzo-p-dioxins
212.           Tetrachlorodibenzofurans
213.           2.3.7.8-fetrach)orodibenzo-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.lect 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,
1,1,2-trichloro-l,2,2-trifluoroethane, and cyclohexanone) have been added
to the list.
    Chemicals are listed in Appendix VIII if they are shown in scientific
studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on
humans or other life-forms, and they include such substances as those
identified by the Agency's Carcinogen Assessment Group as being
carcinogenic.  A waste can be listed as a toxic waste on the basis that
it contains a constituent in Appendix VIII.
    Although Appendix VII, Appendix VIII, and the F003 and F005
ignitables provide a comprehensive list of RCRA-regulated hazardous
constituents, not all of the constituents can be analyzed in a complex
                                    1-25

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

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

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

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

constituents when analytical methods are developed.

    There are five major reasons that constituents were not included on

the BOAT constituent list:

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

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

    3.   The constituent is a member of a chemical group designated  in
         Appendix VIII as not otherwise specified (N.O.S.).  Constituents
         listed as N.O.S., such as chlorinated phenols, are a generic
         group of some types of chemicals for which a iingle 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 1ist .presented in Table 1-1 is divided into the

following nine groups:

        Volatile organics;
       e Semivolatile organics;
       o 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 maximurr
based on the 99th percentile value.
                                    1-29

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

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


nazardous 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

I3DAT 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.
                                    1-45

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             2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION

    The previous section provided the background for the Agency's study
of K046 waste.   The purpose of this section is  to describe the industry
that will  be affected by land disposal restrictions on waste code K046
and to characterize this waste.  This section includes a description of
the industry affected and the production processes employed in this
industry.   Also included is a discussion of how K046 wastes are generated
by these processes.  The section concludes with a characterization of the
K046 waste streams and a determination of the waste treatability group
for this waste.
    The complete list, of hazardous waste codes  from specific sources is
given in 40 CFR 261.32 (see discussion in Section 1 of this document).
Within this list, four specific hazardous waste codes are generated by
the explosives industry.  One of these is the listed waste K046.
2.1    Industry Affected and Process Description
    According to 40 CFR 261.32 (hazardous wastes from specific sources),
waste code K046 is specifically generated from the manufacture,
formulation, and loading of lead-based initiating compounds.  This waste
is 1isted as follows:
    K046:      Wastewater treatment sludges from the manufacturing,
              formulation, and loading of lead-based initiating compounds.
     The four-digit standard industrial classification (SIC) code
reported for the explosives industry is 2892 and includes both commercial
firms and government-owned plants operated by private firms.
                                    2-1

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    The Agency estimates that 62 facilities in the United States are
actively involved in the manufacture, formulation, and loading of
lead-based initiating compounds and could generate K046 waste.
Information from EPA's Hazardous Waste Data Management System (HWDMS)
data base provides a geographic distribution of the number of these
facilities across the United States.
    Tables 2-1 and 2-2 present the location of those facilities that may
generate waste code K046 in each State and EPA region.  As can be seen in
Tables 2-1 and 2-2, these facilities are concentrated in EPA Regions II,
III, V, and VI.  Figure 2-1 illustrates these data plotted on a map of
the United States.  Initiating compounds are generally organic- or
lead-based.  The major organic-based initiating compounds are tetracene,
trinitroresorcinol (TNR), tetry, and nitromannite.  The major lead-based
initiating compounds are lead azide, lead styphnate, and lead
mononitroresorcinate (LMR).
    One manufacturing process for the production of lead azide is
presented below.  The listed waste K046 is generated in the production of
lead azide, as well as in other processes.  As shown in Figure 2-2,
reacting lead nitrate or lead acetate with sodium azide produces lead
azide.  The reaction takes place in a precipitator where the lead azide
product is precipitated and separated from the reaction by-products.  The
precipitate, consisting mainly of lead azide, is washed with water to
remove any traces of impurities and is removed from the washer as the
lead azide product.  The wash water (wastewater) is then further treated
and discharged.
                                    2-2

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               Table 2-1  Facilities Producing K046 by State
State (EPA Region)                                 Number of facilities


Arkansas (IV)                                                 2
California (IX)                                               4
Colorado (VIII)                                               1
Connecticut (I)                                               1
Idaho (X)                                                     3
Illinois (V)                                                  3
Indiana (V)                                                   2
Iowa (VII)                                                    1
Louisiana (VI)                                                5
Maryland (III)                                                2
Massachusetts (I)                                             1
Michigan (V)                                                  2
Minnesota (IV)                                                2
Missouri (VII)                                                2
New Jersey (II)                                               5
New York (II)                                                 3
North Carolina (IV)                                           1
Ohio (V)                                                      4
Oregon  (X)                                                    1
Pennsylvania  (III)                                            3
Texas (VI)                                                    9
Virginia (III)                                                2
West Virginia (III)                                           1
Wisconsin (V)                                                 1
Puerto Rico (II)                                             _1

                                                       Total 62
Reference:  HWDMS, January 1986.
                                    2-3

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            Table  2-2   Facilities  Producing  K046  by  EPA  Region


EPA Region                                          Number of facilities
        I                                                       2
       II                                                       9
      III                                                       8
       IV                                                       1
        V                                                      14
       VI                                                      16
      VII                                                       3
     VIII                                                       1
       IX                                                       4
        X                                                      _4

                                                        Total  62
Reference:  HWDMS, January 1986.
                                    2-4

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no
en
                              Figure  2-1   Facilities Producing K046 by State and by EPA Region

-------
rvj
                                                       WATER
           LEAD NITRATE
           or LEAD ACETATE
           SODIUM AZIDE
                             PRECIPITATOR
               WATER

SODIUM CARBONATE,
           NITRIC ACID
           SODIUM NITRATE
                                PRECIPITATE
                                    FILTRATE
                    TREATMENT
                      TANK
                                  T
                            LEAD CARBONATE
                                SLUDGE
                                (K046)
          IJSCPA Cffluant Gutdnn* Division. Office of Wotr ond Haiordou*
          MoUrtote. Waihlnglon. 0. C. EPA No. 440/176-060. Morch 1976.
                                                          WASHER
                                                             I
                                                      WASTEWATER TO
                                                     FURTHER TREATMENT
  WASTEWATER TO
FURTHER TREATMENT
                           LEAD AZIDE
                            PRODUCT
SLUDGES FROM
TREATMENT OF
WASTEWATER  IS
ALSO K046
                                                                      JIG KIV I  MAK. 26.
                                   Figure 2-2 Lead Azide Manufacture

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    The filtrate from the precipitator goes to a treatment tank where
chemicals are added to chemically transform traces of lead azide into a
mixture of lead carbonate and lead nitrate.  Sodium carbonate,  sodium
nitrite, and nitric acid are generally used as treatment chemicals in the
treatment tank.  Water is also added to the treatment tank to wash the
filtrate stream from the precipitator.  The sludge from the treatment
tank is removed and sent to disposal or further treatment.  This is the
listed waste K046.  The wastewater from the treatment tank is further
treated and discharged.  Sludges from the treatment of these wastewaters
also constitute K046 waste.
    The listed waste K046 is generated in the production of initiating
compounds such as lead azide.  In the production of lead azide, K046 is
generated at the treatment tank.  The filtrate (wastewater) from the
precipitator flows to the treatment tank where chemicals such as nitric
acid, sodium nitrite, and sodium carbonate are added to chemically
transform lead azide in the wastewater to a mixture of lead nitrate and
lead carbonate.  A sludge, consisting mainly of lead carbonate and other
insoluble lead salts, is formed in the treatment tank.  This sludge,
which is the listed waste K046, is removed from the treatment tank and
sent to disposal.
    Wastewater treatment sludges are also generated in the manufacture
and processing of other lead-based initiators, such as lead styphnate and
lead mononitroresorcinate (LMR).  The Agency has no data regarding the
physical and chemical characteristics of the wastewater treatment sludges
                                    2-7

-------
generated by these processes.  However, the Agency has no reason to
believe that the wastewater treatment sludges generated by these
processes are different, for the purpose of treatment, from the K046
waste generated by lead azide production.  Therefore, the Agency will  use
the K046 waste generated by lead azide manufacture to represent the
wastewater treatment sludges generated by the above processes.
2.2      Waste Characterization
    This section includes all waste characterization data available to
the Agency for the K046 waste treatability group.  The major constituents
that comprise this waste and an estimate of their approximate
concentrations are presented in Table 2-3.  The percent concentration of
each major constituent  in the waste was determined from best estimates
based on chemical analyses.  Table 2-3 shows that the major constituent
in K046 is water (95 percent).  The primary BOAT list metal constituent
present in K046 is lead.
    The ranges of BOAT  list constituents present in the waste and all
other available data concerning parameters affecting treatment selection
are presented in Table  2-4.  This table lists the levels of BOAT list
metals present in K046  waste.  Other parameters analyzed in the waste are
also given (sulfate, sulfide, total oil and grease, pH, and total organic
carbon).
    Familiarization samples of K046 were taken by the Agency prior to the
sampling visit.  No BOAT list organics were detected in these samples.
Tables 2-3 and 2-4 together provide a thorough characterization of the
K046 waste.
                                    2-8

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          Table  2-3   Major  Constituent  Composition  for K046 Waste
                                 K046 Waste

   Constituent                                 Concentration (wt.  percent}
Water                                                      95
Lead                                                       <1
Other BOAT List Metals                                     <1
Sodium Sulfide/Sodium Hydroxide                            >3

        TOTAL                                             100
aPercent concentrations presented here were determined based on
 chemical analyses.
                                    2-9

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TABLE 2-4  BOAT CONSTITUENT COMPOSITION AND  OTHER  DATA
     BOAT CONSTITUENTS
DETECTION
  LIMIT
UNTREATED WASTE K046*

   TOTAL     TCLP
       Metals (mg/l)
 154 Antimony
 155 Arsenic
 156 Barium
 157 Beryllium
 158 Cadmiun
 159 Chromium
 160 Copper
 161 Lead
 162 Mercury
 163 Nickel
 164 Selenium
 165 Silver
 166 Thallium
 167 Vanadium
 168 Zinc
     0.02
     0.01
      0.2
    0.005
     0.01
     0.02
    0.025
     0.01
   0.0003
     0.04
    0.005
     0.05
     0.01
     0.05
     0.05
0.022
ND
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
ND
NO
0.295
ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
0.335
     Other Parameters (mg/l)
Sulfate 2
Sulfide 1
Oil & Grease
Total Organic Carbon (Avg.)
pH
190
ND
3.8
461
11.91
NA
NA
NA
NA
NA
        - Values obtained from Onsite Engineering Report for K046 (Waterways
          Experiment Station).
     NA  - Not analyzed.
     ND  - Not detected.
     Note:  Only one sample of K046 was analyzed.  Total organic carbon results
            are an  average of four analyses on the same sample.
                                            2-10

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             3.   APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
              /
    The previous section described the industry that will  be affected by
restrictions on K046 waste and presented a characterization of this
waste.  The purpose of this section is to describe treatment technologies
for K046 waste that EPA has identified as applicable, and  to describe
which of the applicable technologies EPA has determined to be
demonstrated.
3.1      Applicable Treatment Technologies
    Familiarization samples taken by EPA prior to the sampling visit
showed that K046 waste consists primarily of water,  with BOAT list metals
present at treatable concentrations and BOAT list organics present at
uritreatable (de minimis) concentrations.  Because the levels of BOAT list
metals were treatable while the levels of BOAT list  organics were
untreatable, the treatment technologies considered applicable for
treatment of K046 waste are those that treat BOAT list metals.  No
treatment for BOAT list organics is required.
    The EPA has therefore identified the following applicable technology
for treatment of K046 waste:  stabilization using various  binder
materials (cement, kiln dust, and 1ime/flyash).  Metals recovery is not
judged to be an applicable technology because of the relatively low metal
concentrations present.
    Analysis of the K046 sludge indicates that it consists mainly of
water (95 percent).  BOAT constituents constitute less than.2 percent and
non-BDAT constituents (sodium sulfide and sodium hydroxide) constitute
                                    3-1

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greater than 3 percent of the K046 waste.  Of the BOAT list metals
present, lead is present in the highest concentration.  The selection of
the treatment technologies applicable for stabilizing metal constituents
in K046 waste is based on available literature sources (see References)
and field testing.
    For K046 waste, the Agency has identified the following stabilization
technologies as being applicable:  cement-based processes, which use
cement binder additives to chemically bind the metal constituents in a
solidified waste matrix; lime-based processes, which use lime and other
additives to chemically bind the metal constituents in a solidified waste
matrix; and kiln dust (or pozzolan) processes, which use flyash from
cement kilns and lime to chemically bind metal components in a solidified
waste matrix.
3.2      Demonstrated Treatment Technologies
    The Agency believes that none of the above applicable technologies
are currently in commercial use for treating K046 waste.  The Agency
therefore decided to collect performance data for treatment systems that
are demonstrated commercially for wastes similar to K046 (in terms of
parameters affecting treatment selection).
    The following three stabilization processes were tested by the Agency:
      Cement-based process;
      Kiln dust process; and
      Lime/flyash process.
EPA chose to collect performance data for these three stabilization
systems because these systems are currently being used to stabilize
                                    3-2

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wastes similar to K046 (in terms of parameters affecting treatment
selection) on a commercial basis.  A more detailed discussion of these
treatment technology systems follows.
3.3      Detailed Description of Treatment Technologies
3.3.1    Stabilization of Metals
    Stabilization refers to a broad class of treatment processes that
chemically reduce the mobility of hazardous constituents in a waste.
Solidification and fixation are other terms that are sometimes used
synonymously for stabilization or to describe specific variations within
the broader class of stabilization.  Related technologies are
encapsulation and thermoplastic binding; however, EPA considers these
technologies to be distinct from stabilization in that the operational
principles are significantly different.
    (1)  Applicability and use of stabilization.  Stabilization is used
when a waste contains metals that will leach from the waste when it is
contacted by water or a mild acid solution.  In general, this technology
is; applicable to wastes containing BOAT list metals and that have a high
filterable solids content, low TOC content, and low oil and grease
content.  This technology is commonly used to treat residuals generated
from treatment of metallic wastewaters such as those produced by
electroplating.
    (2)  Underlying principles of operation.  The basic principle
underlying this technology is that the stabilizing agent and other
chemicals are added to a waste to minimize the amount of metal that
                                    3-3

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leaches.  The reduced Teachability is accomplished by the formation of a
lattice structure and/or chemical bonds that bind the metals to the solid
matrix and thereby limit the amount of metal constituents that can be
leached when water or a mild acid solution comes into contact with the
stabilized material.
    There are two principal stabilization processes used; these are
cement based and lime based.  A brief discussion of each is provided
below.  In both cement-based or 1ime/pozzolan-based techniques, the
stabilizing process can be modified through the use of additives, such as
silicates, that control curing rates or enhance the properties of the
sol id material.
          (a)  Portland cement-based process.  Portland cement is a
mixture of powdered oxides of calcium, silica, aluminum, and iron,
produced  by kiln burning of material rich in calcium and silica at high
temperatures (i.e., 1400 to 1500C).  When the anhydrous cement
powder is mixed with water, hydration occurs and the cement begins to
set.  The chemistry involved is complex because many different reactions
occur depending on the composition of the cement mixture.
    As the cement begins to set, a colloidal gel of indefinite
composition and structure  is formed.  Over time, the gel swells and forms;
a matrix  composed of interlacing, thin, densely packed silicate fibrils.
Constituents present in the waste slurry (e.g., hydroxides and carbonate;;
of various heavy metals) are incorporated into the interstices of the
cement matrix.  The high pH of the cement mixture tends to keep metals in
                                    3-4

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the form of insoluble hydroxide and carbonate salts.  It has been
hypothesized that metal ions may also be incorporated into the crystal
structure of the cement matrix, but this hypothesis has not been verified.
         (b)  Lime/pozzolan-based process.   Pozzolan, which contains
finely divided, noncrystalline silica (e.g., flyash or components of
ceirent kiln dust), is a material that is not cementitious in itself, but
becomes so upon the addition of lime.  Metals in the waste are converted
to silicates or hydroxides, which inhibit leaching.  Additives, again,
can be used to reduce permeability and,  as  a result, further decrease
leaching potential.
    (3)  Description of stabilization processes.  In most stabilization
processes, the waste, stabilizing agent, and other additives, if used,
are mixed and then pumped to a curing vessel or area and allowed to
cure.   The actual operation (equipment requirements and process
sequencing) will depend on several factors  such as the nature of the
waste, the quantity of the waste, the location of the waste in relation
to the disposal site, the particular stabilization formulation to be
used,  and the curing rate.  After curing, the solid formed is removed
from the processing equipment and shipped for final disposal.
    Waste to be treated, which is contained in lagoons or surface
impoundments and which has a high water content, should first be
dewatered.  The dewatered material or waste not needing dewatering should
then be transferred to mixing vessels where stabilizing agents are
added.  The mixed material is then fed to a curing pad or vessel.  After
                                    3-5

-------
curing, the solid formed is removed for disposal.  Equipment commonly
used also includes facilities to store waste and chemical additives.
Pumps can be used to transfer liquid or light sludge wastes to the mixing
pits and pumpable uncured wastes to the curing site.  Stabilized wastes
are then removed to a final disposal site.
    Commercial concrete mixing and handling equipment generally can be
used with wastes.  Weighing conveyors, metering cement hoppers, and
mixers similar to concrete batching plants have been adapted in some
operations.  Where extremely dangerous materials are being treated,
remote-control and in-drum mixing equipment, such as that used with
nuclear waste, can be employed.
    (4)  Waste characteristics affecting performance.  In determining
whether stabilization is likely to achieve the same level of performance
on an untested waste as on a previously tested waste, the Agency will
focus on the characteristics that inhibit the formation of either the
chemical bonds or the lattice structure.  The four characteristics EPA
has identified as affecting treatment performance are the presence of
(1) fine particulates. (2) oil and grease, (3) organic compounds, and
(4) certain inorganic compounds.
         (a)  Fine particulates.  For both cement-based and
1 ime/pozzolan-based processes, the literature states that very fine solid
materials (i.e., those that pass through a No. 200 mesh sieve, 74 urn
particle size) can weaken the bonding between waste particles and cement
                                    3-6

-------
by coating the particles.  This coating can inhibit chemical bond
formation and thereby decreases the resistance of the material  to
leaching.
         (b)  Oil and grease.  The presence of oil and grease in both
cement-based and 1ime/pozzolan-based systems results in the coating of
waste particles and the weakening of the bonding between the particle and
the stabilizing agent.  This coating can inhibit chemical bond formation
and thereby decrease the resistance of the material to leaching.
         (c)  Organic compounds.  The presence of organic compounds in
the waste interferes with the chemical reactions and bond formation that
inhibit curing of the stabilized material.  This results in a stabilized
waste having decreased resistance to leaching.
         (d)  Sulfate and chlorides.  The presence of certain inorganic
compounds will interfere with the chemical reactions, weakening bond
strength and prolonging setting and curing time.  Sulfate and chloride
compounds may reduce the dimensional stability of the cured matrix,
increasing leaching potential.
    Accordingly, EPA will examine these constituents when making
decisions regarding transfer of treatment standards based on
stabilization.
    (5)  Design and operating parameters.  In designing a stabilization
system, the principal parameters that are important to optimize so that
the amount of Teachable metal constituents is minimized are:
(1) selection of stabilizing agents and other additives, (2) ratio of
                                    3-7

-------
waste to stabilizing agents and other additives, (3) degree of mixing,
and (4) curing conditions.
         (a)  Selection of stabilizing agents and other additives.  The
stabilizing agent and additives used will determine the chemistry and
structure of the stabilized material and thus will  affect the
Teachability of the solid material.  Stabilizing agents and additives
must be carefully selected based on the chemical and physical
characteristics of the waste to be stabilized.  For example, the amount
of sulfates in a waste must be considered when a choice is being made
between a 1ime/pozzolan- and a portland cement-based system.
    To select the type of stabilizing agents and additives, the waste
should be tested in the laboratory with a variety of materials to
determine the best combination.
         (b)  Amount of stabilizing agents and additives.  The amount of
stabilizing agents and proprietary additives is a critical parameter
since there must be enough stabilizing materials in the mixture to bind
the waste constituents of concern properly, making them less susceptible
to leaching.  The appropriate weight ratios of waste to stabilizing agent
and other additives are established empirically by setting up a series of
laboratory tests that allow separate leachate testing of different mix
ratios.  The ratio of water to stabilizing agent (including water in
waste) will also impact the strength and leaching characteristics of  the
stabilized material.  Too much water will cause low strength; too little
will make mixing difficult and, more important, may not allow the
                                    3-8

-------
chemical reactions that bind the hazardous constituents to be fully
completed.
         (c)  Mixing.  The conditions of mixing include the type and
duration of mixing.  Mixing is necessary to ensure homogeneous
distribution of the waste and the stabilizing agents.  Both undermixing
and overmixing are undesirable.  The first condition results in a
nonhomogeneous mixture; therefore, areas will exist within the waste
where waste particles are neither chemically bonded to the stabilizing
agent nor physically held within the lattice structure.  Overmixing, on
the other hand, may  inhibit gel formation and ion adsorption in some
stabilization systems.  As with the relative amounts of waste,
stabilizing agent, and additives within the system, optimal mixing
conditions generally are determined empirically through laboratory
tests.  During treatment it is important to monitor the degree (i.e.,
type and duration) of mixing to ensure that it reflects design conditions,
         (d)  Curing conditions.  The curing conditions include the
duration of curing and the ambient curing conditions (temperature and
humidity).  The duration of curing is a critical parameter to ensure that
the waste particles have had sufficient time in which to form stable
chemical bonds and/or lattice structures.  The time necessary for
complete stabilization depends upon the waste type and the stabilization
used.  The quality of the stabilized waste (i.e., the concentrations of
constituents in the leachate) will be highly dependent upon whether
complete stabilization has occurred.  Higher temperatures and lower
                                    3-9

-------
humidity increase the rate of curing by increasing the rate of



evaporation of water from the solidification mixtures.  If temperatures



are too high, however, the evaporation rate can be excessive.   This can



result in too little water being available for completion of the chemical



reactions associated with the stabilization process.   The duration of the



curing process should also be determined during the design stage and



typically will be between 7 and 28 days.
                                    3-10

-------
                         4.  PERFORMANCE DATA BASE

    This section discusses all  available performance data that EPA has
amassed on the demonstrated technologies discussed in Section 3.
Performance data include the untreated and treated waste concentrations
for a given constituent, the operating values that existed at the time
the waste was being treated, the design values for the treatment
technology, and data on waste characteristics that affect treatment
performance.  EPA has provided all such data to the extent that they are
avail able.
    EPA's use of these data in determining the technology that represents;
BOAT and in the development of treatment standards is discussed in
Sections 5 and 7, respectively.
    For K046, EPA has performance data on stabilization using cement,
kiln dust, and 1ime/flyash.  These data are presented in Tables 4-1
to 4-3.
    The untreated K046 waste and the treated (stabilized) K046 waste for
each sample set were analyzed for BOAT metals, inorganics, and other
parameters.  Also included  in Tables 4-1 through 4-3 are the design
values and actual operating ranges for the key operating parameters of
the cement, kiln dust, and 1ime/flyash processes.
                                    4-1

-------
TABLE 4-1  TREATMENT DATA FOR K046 STABILIZATION  USING  PORTLAND  CEMENT

BOAT CONSTITUENTS
Metals (mg/l)
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
Other Parameters (mg/l)
Sulfate
Sulf ide
Oi 1 & Grease
Total Organic Carbon (Avg.)
PH
* - Treated waste data reflect
NA - Not analyzed.
ND - Not detected (see Appendix
UNTREATED
TOTAL

0.022
ND
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
NO
ND
0.295

190
ND
3.8
461
11.91
analysis of

WASTE
TCLP

ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
0.335

NA
NA
NA
NA
NA
TCLP extracts.


SS 1

ND
ND
1.8
ND
ND
0.033
ND
0.072
0.0003
ND
ND
ND
ND
ND
0.036

NA
NA
NA
NA
NA


TREATED
SS 2

ND
ND
1.8
ND
ND
ND
ND
0.1
ND
ND
 ND
ND
ND
ND
0.027

NA
NA
NA
NA
NA


WASTE*
SS 3

ND
ND
1.8
ND
ND
0.03
0.019
0.062
ND
ND
ND
ND
ND
ND
0.112

NA
NA
NA
NA
NA


C for detection limits).
OPERATING PARAMETERS

Binder to
Waste Ratio*" Run
1.2 A
1.2 B
1.2 C
Dry
Waste 
Water Weight



<9>
600
600
600
Binder
Weight
(9)
720
720
720





Mixture pH
(standard
units)
12.35
12.35
12.35
** EPA checked the data and determined that the treated levels cannot  be obtained
   solely by dilution (due to the high binder/waste ratios).
                                                4-2

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TABLE 4-2  TREATMENT DATA FOR K046 STABILIZATION USING KILN  DUST
     BOAT CONSTITUENTS
 UNTREATED WASTE

TOTAL        TCLP
      TREATED WASTE*

SS 1     SS 2     SS 3
Metals (mg/l)
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
Other Parameters (mg/l)
Sulfate
Sulfide
Oil & Grease
Total Organic Carbon (Avg.)
PH
*  Treated waste data reflect
NA - Not analyzed.
ND  Not detected (see Appendix
OPERATING PARAMETERS

Binder to
Waste Ratio** Run
1.4 A
1.4 B
1.4 C

0.022
ND
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
ND
ND
0.295

190
ND
3.8
461
11.91
analysis of

C for detect

Dry
Watt





ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
0.335

NA
HA
NA
NA
NA
TCLP extracts.

rion liarits).

Waste 
>r Weight
(9)
600
600
600

ND
ND
0.3
ND
ND
0.06
ND
0.9
ND
ND
0.014
ND
0.008
ND
ND

NA
NA
NA
NA
NA




Binder
Weight
(B)
840
840
840

ND
ND
0.4
ND
ND
0.1
0.1
1.1
ND
0.07
0.015
ND
0.009
ND
ND

NA
NA
NA
NA
NA











ND
ND
0.3
ND
ND
0.06
ND
1
ND
ND
0.012
ND
0.007
ND
ND

NA
NA
NA
NA
NA




Mixture pN
(standard
units)
12.25
12.15
12.35
** EPA checked the data and determined that the treated levels  cannot be obtained
   solely by dilution (due to the high binder/waste ratios).
                                                        4-3

-------
TABLE 4-3  TREATMENT DATA FOR K046 STABILIZATION USING LIME/FLYASH
     BOAT CONSTITUENTS
 UNTREATED WASTE





TOTAL     TCLP
      TREATED  WASTE*





SS 1      SS 2      SS 3
Metals (mg/l)
154 Antimony
155 Arsenic
156 Bariun
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
Other Parameters (mg/l)
Sulfate
Sulfide
Oil & Grease
Total Organic Carbon (Avg.)
PH
 - Treated waste data reflect
NA - Not analyzed.
NO - Not detected (see Appendix

0.022
NO
NO 0
NO
NO
NO
NO
967
0.00084
NO
NO
NO
NO
NO
0.295 0

190
NO
3.8
461
11.91

NO
NO
.228
NO
NO
NO
NO
103
NO
NO
NO
NO
NO
NO
.335

NA
NA
NA
MA
NA

NO
NO
3.7
ND
ND
ND
0.008
0.4
HO
ND
NO
ND
0.001 .
ND
0.04

NA
NA
NA
NA
NA

ND
ND
3.5
ND
ND
ND
ND
0.4
NO
0.07
ND
ND
0.002
ND
ND

NA
NA
NA
NA
NA

ND
ND
3.5
ND
ND
ND
0.01
0.4
ND
ND
ND
ND
0.002
ND
ND

NA
NA
NA
NA
NA
analysis of TCLP extracts.





C for detection limits).
OPERATING PARAMETERS
l\mt FlyMh
to to
Waste Waste
Ratio Ratio Run
0.7 0.7 A
0.7 0.7 B
0.7 0.7 C

Dry Waste *
Water Weight

600
600
600

Line
Weight

420
420
420

FlyMh
Weight
(0)
420
420
420








Mixture pH
( standard
units)
12.25
12.15
12.35
                                                       4-4

-------
             5.  IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE
                         TECHNOLOGY  (BOAT)  for K046
    The two previous sections described applicable treatment technologies
for waste code K046 and the available performance data for these
technologies.  This section describes how the performance data collected
by the Agency were evaluated to determine which treatment technology
system should be considered BOAT for waste code K046.  As discussed in
detail in Section 1, this determination essentially involves determining
which of the "demonstrated" technologies will provide the "best"
treatment and, at the same time, be determined to be "available" (i.e.,
the technology can be purchased or licensed and provides substantial
treatment).  Three stabilization techniques are considered in this
section in the selection of BOAT for K046 nonwastewater.  These
techniques are:
      Stabilization using a Portland cement binder,
      Stabilization using a kiln dust binder, and
      Stabilization using a lime/flyash binder.
    As discussed in Section 4, the Agency collected performance data for
the treatment of waste code K046 from these three stabilization systems.
    No additional performance data were available for the treatment of
K046 waste.
    The topics covered in this section include descriptions of the data
screening process employed for selecting BOAT, the methods used to ensure
accuracy of the analytical data, and the analysis of variance (ANOVA)
                                    5-1

-------
tests performed in identifying the best technology for the treatment of
K046 waste.
    In general, performance data are screened according to the following
three conditions:
      Proper design and operation of the treatment system;
      The existence of quality assurance/quality control  measures in
       the data analysis; and
      The use of proper analytical tests in assessing treatment
       performance.
    Sets of performance data that do not meet these three conditions are
not considered in the selection of BOAT.  In addition, if performance
data indicate that the treatment system was not well designed and well
operated at the time of testing, these data also would not be used.
    The remaining performance data are then corrected to account for
incomplete recovery of certain constituents during the analyses.
Finally, in cases where the Agency has adequate performance data for
treatment of the waste by more than one technology, an analysis of
variance (ANOVA) test is used to select the best treatment technology.
5.1      Review of Performance Data
    In the selection of BOAT for treatment of K046 nonwastewater, the
only performance data available were those collected during the Agency's
sampling visit.  Three data sets were collected by the Agency for
treatment of the nonwastewater by stabilization using each of the
following binder materials:  portland cement, kiln dust, and
lime/flyash.  These data were evaluated to determine whether any of the
data represented poor design or poor operation of the system.  None of
                                    5-2

-------
the data sets were deleted because of poor operation of the stabilization
system during the time data were being collected.  Therefore,  all  data
sets were used in the selection of BOAT and the development of treatment
standards for K046 nonwastewater.
    Toxic Characteristic Leaching Procedure (TCLP) data were used  in
setting treatment standards for waste code K046, since BOAT list metals
were present in the untreated waste at treatable levels.  For a
discussion on the use of TCLP data in setting treatment standards, refer
to Section 1 of this background document.
    In instances where a selected constituent was not detected in  the
treated waste, the treated value for that constituent was assumed  to be
the practical quantification level.  This was the case for several of the
BOAT list metal constituents.  Analytical values for the BOAT list metals
of concern in the treated waste are presented in Table 5-1.  These
numbers are taken from Tables 4-1 to 4-3 of this document.
5.2      Accuracy Correction of Performance Data
    After the analytical data were screened as described above, the
Agency adjusted the remaining data using analytical recovery values in
order to take into account analytical interferences and incomplete
recoveries associated with the chemical makeup of the sample.   The Agency
developed the recovery data (also referred to as accuracy data) by first
analyzing a waste sample for a given constituent and then adding a known
amount of the same constituent (i.e., spike) to the waste material.  The
total  amount recovered after spiking, minus the initial concentration in
                                    5-3

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TABLE 5-1   Treatment Data Used for  Regulation of  K046 Waste




BOAT List
Constituent
Cement:
Barium
Lead
Zinc
Kiln Dust:
Barium
Lead
Zinc
Lime/Flyash
Barium
Lead
Zinc
1
Analytical Concentrations

SS 1 SS 2 SS 3
(TCLP) (TCLP) (TCLP)
(mg/l) (mg/l) (mg/l)

1.8 1.8 1.8
0.072 0.1 0.061
0.036 0.027 0.112

0.3 0.4 0.3
0.9 1.1 0.68
<0.02 <0.02 <0.02

3.7 3.5 3.5
0.4 0.4 0.56
0.04 <0.02 <0.02


Matrix
Spike
(TCLP)
(X recovery)

104
77.4
96

108
90.5
69

99
69.5
67

Matrix
Spike
Duplicate Accuracy
(TCLP) Correction
(X recovery) Factor

110 0.96
77.4 1.29
98 1.04

106 0.94
94.5 1.10
72 1.45

84 1.19
77.2 1.44
74 1.49

Accuracy- Corrected

SS 1 SS 2
(TCLP) (TCLP)
(mg/l) (mg/l)

1.728 1.728
0.093 0.129
0.038 0.028

0.282 0.376
0.994 1.215
0.029 0.029

4.140 4.165
0.576 0.576
0.060 0.030
2
Concentrations

SS 3
(TCLP)
(mg/l)

1.728
0.080
0.117

0.282
1.105
0.029

4.165
0.576
0.030



Average
(TCLP)
(mg/l)

1.728
0.101
0.061

0.313
1.105
0.029

4.157
0.576
0.040
    1.   Onsite Engineering Report  for  K046  (Waterways  Experiment Station).
    2.   A sample calculation is  shown  in Appendix B  of  this  Background Document.

-------
the sample, divided by the amount added, is the recovery value.  At least
two recovery values were calculated for spiked constituents, and the
analytical data were adjusted for accuracy using the lowest recovery
value for each constituent.
    Adjustment of the analytical data was accomplished by calculating an
accuracy factor from the percent recoveries for each selected
constituent.  The reciprocal of the lower of the two recovery values,
divided by 100, yields the accuracy factor.  The corrected concentration
for each sample set is obtained by multiplying the accuracy factor by the
uncorrected data value.  The actual recovery values for the selected
constituents are presented in Table 5-1, along with the calculated
accuracy factors.
    The accuracy factors calculated for the selected constituents in K046
varied from a high value of 1.29 for lead to a low value of 0.96 for
barium.  The corrected concentration values for the selected constituents
in the waste are shown for the three treatment systems in Table 5-1.
These corrected concentration values were obtained by multiplying the
accuracy factors by the uncorrected concentration values for the selected
constituents in the treated waste.  An arithmetic average value,
representing the treated waste concentration, was calculated for each
selected constituent from the three corrected values.  These averages are
presented in Table 5-1.  These adjusted values for the three
stabilization techniques tested were then used to determine BOAT for
waste code K046.
                                    5-5

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5.3      Statistical Comparison of Performance Data
    In cases where the Agency has adequate performance data on treatment
of the same or similar wastes using more than one technology, an analysis
of variance (ANOVA) test is performed to determine whether one of the
technologies provides significantly better treatment than the others.  In
cases where a particular treatment technology is shown to provide the
best treatment, the treatment standards will be based on this best
technology.  The procedure followed for the analysis of variance (ANOVA)
test is described in Appendix A.
    To determine BOAT for waste code K046, three demonstrated
technologies, for which adequate performance data were available, were
considered for the treatment of these wastes:
      Stabilzation using a portland cement binder,
      Stabilization using a kiln dust binder, and
      Stabilization using a lime/flyash binder.
    The corrected data for all sample sets were used to perform analysis
of variance (ANOVA) tests to compare these three stabilization
technologies.  The three treatment technologies were compared based on
the concentration of primary waste constituent (lead) in the treated
waste.  The rationale for selecting this constituent for the ANOVA
comparison is presented in Section 6.  The ANOVA calculations are
summarized in Appendix D.
    The statistical results of the ANOVA test for K046 waste indicate
that stabilization using a portland cement binder gives better treatment
                                    5-6

-------
for lead in K046 than stabilization using a kiln dust or lime/flyash
binder.
5.4      BOAT for K046 Waste
    Stabilization using a portland cement binder provides significantly
better or equivalent treatment overall for the primary constituents
present in waste code K046 when compared to either stabilization using a
kiln dust binder or stabilization using a lime/flyash binder.  Therefore,
the Agency determined stabilization using a portland cement binder to be
BOAT for waste code K046.
    Based on the water content of this waste, EPA recommends physical
dewatering processes prior to stabilization to reduce the binder-to-waste
ratio necessary to achieve effective stabilization of the waste.
Stabilization is judged to be available to treat K046 nonwastewater.  The
Agency believes this technology to be available because (1) it is
commercially available and (2) it provides a substantial reduction in the
levels of BOAT list constituents present in K046 waste (see Table 5-2).
                                    5-7

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                            TABLE 5-2  K046 NONWASTEWATER DATA SHOWING SUBSTANTIAL TREATMENT BY CEMENT  STABILIZATION
                            Constituent
UNTREATED WASTE
Total
Composition    TCLP
(rng/l)         (mg/l)
                             Sample
                             Set #1
                             (mg/l)
TREATED WASTE'
Sample
Set #2
(mg/l)
Sample
Set #3
(mg/l)
                                K046
                                Lead
967
103
                                                                                                   0.072
                                                              0.1
                  0.062
en
 i
00
                            * - Treated waste data reflect analysis of TCLP extracts and corrected for accuracy.

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                  6.  SELECTION OF REGULATED CONSTITUENTS

    As discussed in Section 1, the Agency has developed a list of
hazardous constituents (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 K046.  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.
    As discussed in Sections 2 and 4, the Agency has characterization
data as well as performance data from treatment of K046.  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 K046 nonwastewater.
    Table 6-1 shows which constituents were analyzed, which constituents
were detected, and which constituents the Agency believes to be present
even though they were not detected in the untreated waste.
    Under the column "Believed to Be Present," constituents other than
those detected in the untreated waste are marked with a Y if EPA believes
they are likely to be present in the untreated waste.  Those constituents
                                    6-1

-------
TABLE 6-1  BOAT List Metals Detected in Untreated Waste
         Parameter
                                        Total
                                               Untreated
                                                         TCLP
Believed to
be present
  Metals (ing/1)
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
Antimony
Arsenic
Bariifn
Beryl I ium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Se I en i urn
Si Iver
Thai 1 ium
Vanadium
Zinc
.022
ND
ND
ND
ND
ND
ND
967
.00084
ND
ND
ND
ND
ND
.295
ND
ND
.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
.335


Y


Y
Y

Y






 D - Detected
ND - Not detected
                                                     6-2

-------
marked with a 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 specific waste is defined as being generated by a
process and the process can involve a number of different constituents,
only some of which would be present in any given sample.
    As shown in Table 6-1, four constituents have been detected and four
have been identified as believed to be present.  Of the detected
constituents, EPA has selected only one for regulation (lead).  Of the
three not being regulated, none is believed to be treatable.  EPA is not
regulating these three constituents because they are found at
concentrations far below the regulated constituent.
                                    6-3

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                7.  CALCULATION OF BOAT TREATMENT STANDARDS

       In this section, the actual treatment standards for waste code
K046 are presented.  These standards were calculated based on the
performance of the demonstrated treatment system that was determined by
the Agency to be the best for treating both waste codes.   In Section 4,
BOAT for waste code K046 was determined to be stabilization using a
Portland cement binder.  The previous section identified the constituents
to be regulated for waste code K046.
    As discussed in Section 1, the Agency calculated the BOAT treatment
standards for waste code K046 by following a four-step procedure:
(1) editing the data;  (2) correcting the remaining data for analytical
interference; (3) calculating adjustment factors (variability factors) to
account for process variability; and (4) calculating the actual treatment
standards using variability factors and average treatment values.  The
four steps in this procedure are discussed in detail in Sections 7.1
through 7.4
7.1      Editing the Data
    Three sets of treatment data for waste code K046 were collected by
the Agency at one facility that operated a treatment system consisting of
stabilization using a  portland cement binder.  The Agency evaluated the
three data sets to determine whether the treatment system was well
operated at the time of the sampling visit.  The operating data collected
indicate that the treatment system was well operated during the
collection of all data sets.  For further details on the three data sets,
                                    7-1

-------
see the Onsite Engineering Report for K046 (USEPA 1988).  All of the
available data sets were used to calculate treatment standards.
    Toxic Characteristic Leaching Procedure (TCLP) data were used in
setting treatment standards for waste code K046, since BOAT list metals
were present in the untreated waste at relatively high concentrations.
For a discussion on the use of TCLP data in setting treatment standards,
refer to Section 1 of this background document.
    In instances where a selected constituent was not detected in the
treated waste, the treated value for that constituent was assumed to be
the Practical Quantification Level.  This was not the case for any of the
regulated constituents in K046.  Analytical values for the treated waste
are presented in Section 4, Tables 4-1 through 4-3 of this report.
7.2      Correcting the Remaining Data
    Data values for the constituents selected for regulation were taken
from the three data sets.  These values were corrected in order to take
into account analytical interferences associated with the chemical makeup
of the treated sample.  This was accomplished by calculating an accuracy
factor from the percent recoveries for each selected constituent.  The
reciprocal of the lower of the two recovery values, divided by 100,
yields the accuracy factor.  The corrected concentration for each
constituent in each sample set is obtained by multiplying the accuracy
factor by the uncorrected data value.  The calculation of recovery values
is described in Section 1 of this background document.  The actual
                                    7-2

-------
recovery values and accuracy factors for the selected constituents are
presented in Table 5-1.
    The accuracy factor calculated for lead in K046 was 1.29.  The
corrected concentration values for the selected constituent are shown for
the three data sets for cement stabilization in Table 7-1.  These
corrected concentration values were obtained by multiplying the accuracy
factors by the concentration values for the selected constituent in the
treated waste.  An arithmetic average value, representing the treated
waste concentration, was calculated for the selected constituent from the
three corrected values.  This average is presented in Table 7-1.
7.3      Calculating the Variability Factors
    It is expected that in normal operation of a well-designed and
well-operated treatment system there will be some variability in
performance.  Based on the test data, a measure of this variability is
expressed by the variability factor (see Appendix A).  This factor was
calculated for the selected regulated constituent.  The methodology for
calculating variability factors is explained in Appendix A of this
report.  Table 7-1 presents the results of calculations for the selected
constituent.  Appendix D of this report shows how the actual value in
Table 7-1 was calculated.
    The variability factor calculated for lead in K046 was 1.76.  For
comparison, a variability factor of 1.0  represents test data from a
process measured without variation and analytical interferences.
                                    7-3

-------
                                                                                                           1
                 TABLE 7-1   Regulated Constituents and Calculated Treatment Standards for K046  Nonwastewaters
Accuracy-Corrected

Sample
Set #1
Constituent
Concentration (mg/l)

Sample Sample
Set #2 Set #3
Average
Treated
Waste
Concentration
(mg/l)

Variabi I ity
Factor
(VF)
Treatment
Standard
(Average
X VF)
 K046
 Lead
                            0.093
0.129
0.079
                  0.100
                                    1.76
0.18
1 -  Accuracy Correction Factors and Variability Factors were determined as discussed in Appendix  D.

-------
7.4      Calculating the Treatment Standards



    The treatment standard for the selected constituent was calculated by



multiplying the variability factor by the average concentration value for



the treated waste.  The treatment standard is presented in Table 7-1.



    The BOAT treatment standard for waste code K046 is as follows:



    Constituent                         TCLP extract (mo/I)



       Lead                                     0.18
                                    7-5

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                            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 and by Jacobs Engineering, acting as a subcontractor to
Versar Inc.  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 K046 nonreactive waste.  The Technical Project Officer for the
waste was Mr. Juan Baez-Martinez.  Mr. Steven Silverman served as legal
advisor.
    Versar personnel involved with preparing this document included
Mr. Jerome Strauss, Program Manager; Ms. Justine Alchowiak, quality
assurance officer; Mr. David Pepson, senior technical reviewer; and
Ms. Juliet Crumrine, technical editor.  Jacobs personnel included
Mr. Alan Corson, Quality Assurance/Quality Control Manager; Mr. Ramesh
Maraj, project manager; Mr. Bradford Kauffman, engineering team leader;
and Ms. Rosetta Swann, project secretary.
    The K046 treatment test was executed at Waterways Experiment Station,
Vicksburg, Mississippi.  Field sampling for the test was conducted under
the leadership of Mr. William Myers of Versar; laboratory coordination
was provided by Mr. Jay Bernarding, also of Versar.
    We greatly appreciated the cooperation of Remington Arms Company,
Inc., Bridgeport, Connecticut, for providing the test samples of the K046
                                    8-1

-------
waste, and the individual companies and trade associations that submitted
information to the U.S. EPA.
                                    8-2

-------
                               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

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.

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

Cullinane, J.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.

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

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

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

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

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

USEPA.  1988.  U.S. Environmental Protection Agency.  Onsite
    engineering report for K046.  Office of Solid Waste.
    Washington, D.C.:  U.S. Environmental Protection Agency.

                                     9-1

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                                APPENDIX A
                            STATISTICAL METHODS

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

                                    A-l

-------
                Table A-l
95th PERCENTILE VALUES FOR
    THE F DISTRIBUTION
 decrees of freedom for numerator
 decrees of freedom for denominator
      (shaded area = .95)
\*
"A
1
O
ft
O
1
5
C
i
8
Q
10
11
12
13
14
15
16
17
18
19
20
ft ft
24
26
28
30
40
50
60
70
80
100
150
200
400

1

161.4
16.51
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
4.4C
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.S7
2.S2
2.78
2.74
2.71
2.69
2.61
2.56
2.53
2.50
2.48
2.46
2.43
2.41
2.39
2.37
6

230.2
19.30
9.01
6.26
5.05
4.39
3.97
3.69
3.48
3.33
3.20
3.11
3.03
2.96
2.90
2.85
2.81
2.77
2.74
2.71
2.66
2.62
2.59
2.56
2.53
2.45
2.40
2J7
2.35
2.33
2.30
2J!7
2.26
2.23
2^1
6

234.0
19.33
8.94
6.16
4.95
4.28
3.87
3.58
3.37
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
2.66
2.63
2.60
2.55
2.51
2.47
2.45
2.42
2.34
2JJ9
2J25
223
2.21
2.19
2.16
2.14
2J.2
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
229
221
2.18
2.13
2UO
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
2J1
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

24C.3
19.43
8.69
5.84
4.60
3.92
3.49
3.20
2.98
2.82
2,70
2.60
2.51
2.44
2.39
2.33
oj>g
2-25
2.21
2.18
2J3
2.09
2.05
2.02
1.99
1.90
1.85
1.81
1.79
1.77
1.75
1.71
1.69
1.67
1.64
20

248.0
19.45
8.66
5.80
4.56
3.87
3.44
3.15
2.93
2.77
2.65
2.54
2.46
2-39
2.33
2.28
2-23
2.19
2.15
2.12
2.07
2.03
1.99
1.96
1.93
1.84
1.78
1.75
1.72
1.70
1.68
1.64
1.62
1.60
1.57
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
*> **5
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.S7
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40

251.1
19.46
8.CO
5.71
4.46
3.77
3.34
3.05
2.82
2.67
2.53
2.42
2.34
2.27
2 **1
2.16
2.11
2.07
2.02
1.99
1.93
1.89
1.85
1.81
1.79
1.69
1.63
1.59
1.56
1.54
1.51
1.47
1.46
1.42
1.40
50

252 2
19.47
8.58
5.70
4.44
3.75
3.32
3.03
2.80
2.64
2.50
2.40
2.32
2.24
2.18
2.13
2.08
2.04
2.00
1.96
1.91
1.86
1.82
1.78
1.76
1.66
1.60
1.56
1.53
1.51
1.48
1.44
1.42
1.38
1.32
100

253.0
19.49
8.56
5.6C
4.40
3.71
3.28
2,98
2.76
2.59
2.45
2.35
2.26
2.19
2.12
2.07
2.02
1.98
1.94
1.90
1.84
1.80
1.76
1.72
1.69
1.59
1.52
1.48
1.45
1.42
1.39
1.34
1.32
1.28
1.24


25;.3
19.50
S.53
5,63
4..3G
3..6T
3.23
2..93
2..71
2..S-;
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:
   SSB =
where:
k
                  Tj
                  n.
(,1,"
                                  2 1
         = 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:
SSW =
where:
' k
.1
I'
X2.
        k
      - z
                                        T.
         = 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-l) 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 tf fluent
Ug/D
1550.00
1?90.00
1640.00
5100.00
1450.00
4600.00
1760.00
2400.00
4UOO.OO
12100.00
(rt/U
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 tffluent In(effluent)

2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
Ug/1) Ug/M
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
[ln(eff luent)]2

5.29
5.29
5.29
10. G3
5.29





Sum:
                                 23.18
                                                   53.76
                                                             12.46
                                   31.79
Sample Si/c:
    10           10

Hean:
  3669           10.2

Standard Deviation:
  3328.6/          .63
Variabi1ity factor:
10
 2.32
  .06
                              2378
                               923.04
                  1.15
13.2
                                                7.15
                                                                                 2.48
                                                             2.49
                                                               .43
ANOVA Calculations:


SSB =

2
k T '
i = l 	
'






-

(^
 T i
i = l
2


N J
,-r,, _ \ IS, "i ..:> 1 * f ('2





MSB = SSB/(k-l)

MSW -- SSW/(N-k)
                                                           A-5

-------
1790g


                                     Example 1  (Continued)
F   = MSB/MSW

where:

k   = number of treatment, technologies

n.  = number of data points for technology i

N   - number of natural  logtransformed data points for all technologies

T.  = sum of logtransformcd data points for each technology

X   - the nat.  logtransformed observations (j) for treatment technology (i
n  = 10. n  = 5. N = 15. Ic = Z. T  = 23.18. T  = 12.46.  T - 35.64.  T = 1270.21

T2 = 537.31  T? = 155.25

     .  537.31   155.25 1    1270.21
SSB = 	 + 	   - 	       =  0.10
                                                   - 0.77
        10        5    I      15
SSU - (53.76  31.79) -


MSB = 0.10/1 = 0.10

MSW - 0. 77/13 - 0.06

F  .  i!L  =1.67
      0.06
                          537.31   155.25
                           10
                                    ANOVA Table
Degrees of
Source freedom
Between) 8) 1
Withm(W) 13

SS HS F vdlue
0.10 0.10 1.67
O.// 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 mentis are not siyrnf icanL ly
      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
                                                        Irichloroethylene
S_team stripping
Inf luent
(M9/1)
1650.00
5200.00
5000 . 00
1720.00
1560.00
10300.00
210.00
1600.00
204 . 00
160.00
Effluent
Ug/U
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
85.00
10.00
ln(eff luent)

2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30
[In(effluent)]2

5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
Influent
(M9/1)
200.00
224.00
134.00
150.00
484 . 00
163.00
182.00



Biological trea tmen t
Effluent
Ug/l)
10.00
10.00
10.00
10.00
16. 2b
10.00
10.00



ln(eff luent)

2.30
2.30
2.30
2.30
2./9
2.30
2.30



[ln(f.-ff luent)]2

0.29
5.29
5.?9
5.29
/./b
b.29
5.29



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

Vdridbi I ity FdcLor:
                  3.70
                                 26.14
                10
                 2.61
                  .71
                                                  72.92
220
120.5
                                                              10.89
2.36
                                                               1.53
                                                                             16.59
               2.37
                                 .19
                                                  39.52
ANOVA Calculations:


SSB --



k
Z
i-1

2 1
1,

n . J
i


-


f Z T ]2

1 i = 1 I

L N J





      r  k   ni
SSW =    2   

MSB = SSB/(k-l)

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

-------
1790g


                                     Example 2  (Continued)

F   - MSB/MSV

where:

k   - number of treatment technologies

n   - number of data points for technology i

N   = number of data points for all technologies

T   - sum of natural logtransformed data points for  each technology

X   = the natural logtransformcd observations (j)  for treatment  technology  (i)


N  = 10. N  - /. N - 17.  k - 2. I  - 26.14.  \  - 10.59,  I  -  42.73.  I  -  1825.85.  I?  -  683.30.
T  = 275.23
SSB
     ( 10            7


SSW = (/2.92 *- 39.52) -


MSB - 0.25/1 = 0.25

MSU = 4.79/15 = 0.32

F =	 = 0.78
    0.32
     1825.85

       17

 683.30   2/5.23
	 +  	
   10        7
                                              =  0.?5
                                                -  4.79
                                    ANOVA Table
Degrees of
Source freedom
Between(B) 1
Within(W) 15

SS MS
0.25 0.25
4.79 0.32

F value
0.78

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

-------
1790g
Example 3
Chlorobenzene
Activated :; lurtqc followed
Influent Effluent
Ug/1) Ug/1)
7200.00 80.00
6500.00 70.00
6075.00 35.00
3040.00 10.00



Sum:
Sample Size:
4 4
Mean:
5703 49
by carbon adsorption Biolonic.il treatment
In(effluent) [ln(eff luent)]2 Influent
Ug/l)
4.38 19.18 9206.00
4.25 18.06 16646.00
3.56 12.67 49775.00
2.30 5.29 14731.00
3159.00
6756.00
3040.00
14.49 55.20

4 - 7

3.62 - 14759
Effluent
Ug/D
1083.00
709.50
460.00
142.00
603 . 00
153.00
17.00
-

/

452.5
In(effluent) ln((eff luent )]2

6.99 48.86
6.56 43.03
6.13 3/.5B
4.96 24.60
6.40 40 96
5.03 25.30
2.83 8.01
38.90 228.34

/

5.56
Standard Deviat ion:

   1835.4       32.24
Variabi I ily Factor:
          .95
16311.86
                7.00
379.04
                                                                        15.79
                               1.42
ANOVA Calculations


               2
       k  i   i
SSB -   .Z



        k
HSB = SSB/(k-l)



MSW = SSW/(N-k)



I-   -- HSU/HSU

  k   f Tj2 \

-A  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

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


N  = 4.  N = 7.  N = 11.  k = 2. T  = 14.49.  T  = 38.90. T = 53.39.  T?=  2850.49.  I?  =  209.96
I   - 1S13.21
SSB -
      209.96     1513.21
2850.49
                                11
                -  9.52
SSW = (55.20 + 228.34)
                            209.96    1513.21
                                   f
                         = 14.88
MSB = 9.52/1 = 9.52

MSW - 14.88/9 - 1.65

K - 9.52/1.65 - 5.77
                                    ANOVA Table
Degrees of
Source freedom
Bctwccn(B) 1
Uithin(W) 9

SS
9.53
14.89

MS F value
9.53 5.77
1.65
      The critical value of the F tost at the 0.05 significance level  is 5.1?.   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.   Kesults may differ depending
       upon the number of decimal places used in each slop of the calculations.
                                          A-10

-------
A.2  Variability Factor
                                     Cgg
                              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 = txp(y + 2.33 Sy)
               where y and Sy are the mean and standard deviation,
               respectively, of the logtransformed data; and
    Mean    =  average of the individual performance values.

    EPA is establishing this figure as an instantaneous maximum because

the Agency believes that on a day-to-day basis the waste should meet the

applicable treatment standards.  In addition, establishing this

requirement makes it easier to check compliance on a single day.  The

99th percentile is appropriate because it accounts for almost all process.

variabi1ity.

    In several cases, all the results from analysis of the residuals from

BOAT treatment are found at concentrations less than the detection

limit.  In such cases, all the actual concentration values are considered

unknown and,  hence, cannot be used to estimate the variability factor of

the analytical results.  Below is a description of EPA's approach for

calculating the variability factor for such cases with all concentrations

below the detection limit.

    It has been postulated as a general rule that a lognormal

distribution adequately describes the variation among concentrations.

Agency data show that the treatment residual concentrations are
                                    A-ll

-------
distributed approximately lognormally.  Therefore, the lognormal model

has been used routinely in the EPA development of numerous regulations in

the Effluent Guidelines program and is being used in the BOAT program.

The variability factor (VF) was defined as the ratio of the 99th

percentile (C  ) of the lognormal distribution to its arithmetic mean

(Mean), as follows:


           VF =     C99.                                    ^
                   Mean

    The relationship between the parameters of the lognormal  distribution

and the parameters of the normal distribution created by taking the

natural logarithms of the lognormally distributed concentrations can be

found in most mathematical statistics texts (see, for example,

Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970).  The mean

of the lognormal distribution can be expressed in terms of the

mean (n) and standard deviation (a) of the normal distribution as

follows:

         C9g    =  Exp (M +  2.33a)                        (2)

         Mean   =  Exp (M +  0.5a2).                       (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 - Q.5o2).                       (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/LLJ] / 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 waste concentrations.
    SW-846 allows for the use of alternative or equivalent procedures or
equipment; these are described 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 factor determination for a constituent is based on the
matrix spike recovery values.  Table B-3 presents the matrix spike
recovery values for TCLP extract concentrations of BOAT list metals and
non-BDAT list metals for K046.
    The accuracy-correction factors were determined in accordance with
the general methodology presented in the Introduction.  For example, for
lead, actual spike recovery data were obtained for analysis of liquid
matrices, and the lowest percent recovery value was used to calculate the
accuracy-correction factor.  An example of the calculation of the
corrected concentration value for lead in K046 (using a cement binder) is
shown below.  The analytical value is the uncorrected concentration from
Table 4-1 (or Table B-3).  The percent recovery value is taken from
Table B-3.
                                    B-l

-------
                    TABLE B-1   Analytical  Methods
                Analytial Method
Method No.    Reference
Inductively Coupled Plasma
  Atomic Emission Spectroscopy
  (aluminum/antimony/barium/beryl Iium/
  cadmium/caIcium/chromium/cobaIt/copper/
  i ron/magnes i um/manganese/nickel/s iIver/
  sodium/tin/vanadium/zinc/lead)
  6010
Arsenic (Atomic Absorption, Furnace Technique)
Selenium (Atomic Adsorption, Furnace Technique)
Mercury in Liquid Waste (Manual Cold-
Vapor Technique)
Lead (Atomic Adsorption, Furnace Technique)
Thallium (Atomic Adsorption, Furnace Technique)
Hexavalent Chromium
TCLP
TOC
Chloride
Sulfate
Oi 1 and Grease
Particle Size Distribution
7060
7740
7470
7421
7841
7196
51 FR 40643
9060
9252
9038
9071
0 422
1
1
1
1
1
1
2
1
1
1
1
3
References:

1.  U.S. Environmental Protection Agency.   1986.   Test Methodology for
    Evaluating Solid Waste.  Third Edition,  U.S.  E.P.A. Office of Solid Waste
    and Emergency Response, November 1986.

2.  Federal Register, 1986.  Hazardous Waste Management Systems;  Land Disposal
    Restrictions; Final Rule; Appendix I  to Part  268 - Toxicity Leaching
    Procedure (TCLP).  Vol. 51,  No. 216.   November 7,  1986.   pp.  40643-40654.

3.  American Society for Testing and Materials.   1986.  Annual Book of ASTM
    Standards.  Philadelphia, PA.  1986.
                                         B-2

-------
                      TABLE 8-2 Specific Procedures or Equipment Used in Preparation and Analysis of Metals
                                 When Alternative or Equivalents Allowed in the SU-846 Methods
Analysis
SW-846
Method Equipment
Alternative or Equivalent
Allowed by SW-846 Methods
Specific Procedures or
Equipment Used
Inductively coupled
plasma atomic
emission spectroscopy
6010   Perkin Elmer
       Plasma II Emission
       Spectrophotometers
 Operate equipment  following
  instructions provided by
  instrument's manufacturer.
 Equipment operated using
  procedures specified in the
  Perkin Elmer Plasma II
  Emission Spectrophotomcter
  Operator's Manual.
                                                         For operation with organic
                                                          solvents, auxiliary argon gas
                                                          inlet  is recommended.
                                                                  Auxiliary argon gas was not
                                                                   required for sample matrix.
Metals by Furnace AA
  Thallium              7841
  Selenium               7740
  Lead                   7421
  Arsenic                7060
       (1) Perkin Elmer 560    Operate equipment following
       (2) Perkin Elmer HGA
           2200 Graphite
           Furnaces
  instructions provided by
  instrument's manufacturer.
 Equipment operated usiig
  procedures specified in
  Perkin Elmer instruction
  manuaIs.
                                                       t  For background correction
                                                          use either continuous
                                                          correction or alternatives,
                                                          e.g., Zeeman correction.
                                                                  Background detection was
                                                                   used.
                                                          If samples contain a large
                                                          amount of organic material,
                                                          they should be oxidized by
                                                          conventional acid digestion
                                                          before being analyzed.
                                                                  Sample preparation using a
                                                                   hydrochloric acid digestion
                                                                   was not used.
Mercury
                         7471   Perkin Elmer  560
                               Operate equipment following
                                instructions by instrument's
                                manufacturer.
                                    Equipment operated us'ng
                                     procedures specified '.n Perkin
                                     Elmer 560 Instruction Manual.
                                                          Cold  vapor apparatus is
                                                          described in SU-846 or an
                                                          equivalent apparatus may be
                                                          used.
                                                                  Mercury was analyzed by cold
                                                                   vapor method using this
                                                                   apparatus as specified in
                                                                   SU-846.
                                                          Sample may be prepared using
                                                          the  water bath method or the
                                                          autoclave method described  in
                                                          SW-846.
                                                                  Samples were prepared using
                                                                   the water bath method.
                                                                B-3

-------
                              TABLE B-3    Matrix Spike  for Metals for the TCLP Extract
                                                 for  the  Cement Binder
                                                         K046
Spike
Constituent
BOAT Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium-total
Chromi urn- hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai I ium
Vanadium
Zinc
Non-BDAT Metals
Aluminum
Calcium
Coba I t
Iron
Magnesium
Manganese
Sodium
Tin
Original
Amount
Found
(mg/l)

<0.017
<0.003
1.8
<0.002
<0.005
<0.03
<0.06
<0.019
<0.061
<0.0003
<0.03
<0.002
<0.006
<0.001
<0.008
<0.02

0.311
2140
<0.04
<0.112
0.025
<0.002
331
<0.983
Amount
Spiked
(mg/l)

1
0.1
1
1
1
1
1
1
1
0.05 .
1
0.05
1
1
1
1

1
1
1
1
1
1
1
1
Matrix
Amount
Found
(mg/l)

0.96
0.118
2.84
0.89
0.96
0.98
0.38
0.86
0.82
0.0471
0.88
0.054
0.25
0.2
0.91
1.07

1.20
NC
0.93
0.93
0.92
0.93
NC
0.60
Spike
Percent
Recovery

96
118
104
89
96
95
94
84
77
94
88
108
25
20
91
96

89
NC
93
82
90
93
NC
60
Matrix
Amount
Found
(mg/l)

0.95
0.113
2.90
0.96
0.99
0.98
NA
0.82
0.82
0.0505
0.98
0.043
0.42
0.15
0.95
1.09

1.19
NC
0.90
0.98
0.99
0.96
NC
0.76
Spike Oupl icate
Percent
Recovery

95
113
110
96
99
95
NA
81
77
101
98
87
42
15
95
98

88
NC
90
86
96
96
NC
76
Relative
Percent
Recovery

1
t.
(,
a
:s
0
NC
I*
0
7
11
22
51
29
4
2

1
NC
3
5
6
3
NC
24
NA -  Not Analyzed
NC -  Not Calculatable
*
 Percent Recovery = 100(C  - C )/C ,  where C  is the initial  concentration. C   is  the concentration of
                         i     o   t         o                                i
 the  spiked aliquot, and C   is the concentration of  the  spike added.
*
  Relative Percent Difference - 100 (D  -  D /(D  + D?)/2),  where D  ,  is  the larger of the two observed
  values for Percent Recovery
                                                                                                               continued
                                                           B-4

-------
                              TABLE  B-4     Matrix  Spike for  Metals  for  the TCLP Extract
                                                 for  the Kiln Dust
                                                          IC046
Spike
Constituent
BOAT Hetals
Antimony
Arsenic
Barium
Beryl lium
Cadmium
Chromium- total
Chromi urn- hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai I ium
Vanadium
Zinc
Non-BDAT Hetals
Aluminum
Calcium
Cobalt
Iron
Magnes i urn
Manganese
Sodium
Tin
Original
Amount
Found
(mg/l)

<0.017
<0.003
0.3
<0.002
<0.005
0.06
0.06
<0.006
0.68
<0.0003
<0.03
0.012
<0.006
0.007
<0.008
<0.002

<0.016
2134
<0.04
<0.02
0.02
<0.002
201
<0.983
Amount
Spiked
(mg/l)

1
0.1
1
1
1
1
1
1
1
0.05
1
0.05
1
1
1
1

1
1
1
1
1
1
1
1
Matrix
Amount
Found
(mg/l)

0.85
0.115
1.38
0.70
0.77
0.85
1.29
0.83
1.52
0.0540
0.74
0.058
0.13
0.55
0.86
0.69

0.89
NC
0.77
0.71
0.76
0.89
NC
0.67
Spike
Percent
Recovery

85
115
108
70
77
79
123
83
91
108
74
91
13
55
86
69

89
NC
77
71
74
89
NC
67
Matrix
Amount
Found
(mg/l)

0.92
0.122
1.36
0.72
0.73
0.87
1.23
0.83
1.59
0.0575
0.73
0.067
0.32
0.51
0.88
0.72

0.87
NC
0.81
0.76
0.78
0.76
NC
0.70
Spike Dupl icate
Percent
Recovery

92
107
106
72
73
81
117
83
95
115
73
110
32
51
88
72

87
NC
81
76
76
76
NC
71
Relative
Percent
**
Recovery

,
'>
6
13
:s
D
-
*
4
7
11
22
84
8
4
2

1
IIC
3
5
6
3
MC
24
NA - Not Analyzed
NC - Not Calculatable
*
 Percent Recovery = 100(C  - C )/C ,  where C  is the initial  concentration.  C   is  the concentration of
                         i     o   t         o                                i
 the spiked aliquot, and C  is the concentration of the spike added.
**
  Relative Percent Difference  100 (D    0?/(0  * 0.,)/2),  where D  ,  is  the  larger of the two observed
  values for Percent Recovery
                                                                                                               continued
                                                              B-5

-------
                          TABLE  B-5     Matrix Spike for  Metals  for the TCLP Extract
                                             for the Fly  Ash  Binder
                                                      K046
Spike
Constituent
BOAT Hetals
Antimony
Arsenic
Barium
Beryl I iurn
Cadmium
Chromium-total
Chromi urn- hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai lium
Vanadium
Zinc
Non-BDAT Metals
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Sodium
Tin
Original
Amount
Found
(mg/l)

<0.017
<0.003
3.5
<0.002
<0.005
<0.02
<0.064
0.01
0.56
<0.0003
<0.03
<0.002
<0.006
0.002
<0.008
<0.02

0.2
2366
<0.04
<0.02
0.003
<0.002
280
<0.983
Amount
Spiked
(mg/l)

1
0.1
1
1
1
1
1
1
1
0.05
1
0.05
1
1
1
1

1
1
1
1
1
1
1
1
Matrix
Amount
Found
(mg/l)

0.74
0.122
4.49
0.66
0.69
0.75
0.94
0.84
1.08
0.0489
0.67
0.37
0.22
0.68
0.87
0.67

1.16
NC
0.77
0.76
0.79
0.78
NC
0.77
Spike
Percent
Recovery

74
122
99
66
69
75
94
83
70
98
67
75
22
67
87
67

96
NC
77
76
79
78
NC
77
Matrix Spike Duplicate
Amount
Found Percent
(mg/l) Recovery

0.77
0.124
4.34
0.72
0.69
0.82
NA
0.83
1.20
0.0458
0.74
0.037
0.39
0.71
0.86
0.74

1.12
NC
0.79
0.75
0.77
0.77
NC
0.70

77
124
84
72
69
82
NA
82
77
92
75
74
39
71
86
74

92
NC
79
75
77
77
NC
70
Rel ative
Percent
**
Recovery

t
c'.
16
9
1)
i)
NC
1
10
6
11
1
56
6
1
9

4
NC
3
1
3
1
NC
10
NA - Not Analyzed
NC - Not Calculatable

 Percent Recovery = 100(C  - C )/C ,  where C  is the initial  concentration, C.  is the concentration of
                         i     o   t         o                                i
 the spiked aliquot, and C  is the concentration of the spike added.
*
  Relative Percent Difference - 100 (D   D /(D  + D )/2),  where D ,  is  the larger of the two observed
  values for Percent Recovery
                                                                                                               cont i nued
                                                          B-6

-------
Analytical                         Correction           Corrected
  value          % Recovery          factor      	value	

0.061 mg/1           77           100 = 1.30     1.30 x 0.061 = 0.079 mg/1
                                   77
                                    B-7

-------
                                APPENDIX C

                     DETECTION  LIMITS  FOR UNTREATED AND
                            TREATED K046 WASTE
    Table C-l shows detection limits for the metal  constituents in

untreated K046 waste.  Table C-2 shows detection limits for three types

of stabilized K046 waste.
                                    C-l

-------
TABLE C-1  DETECTION  LIMITS  FOR UNTREATED K046
                                   DETECTION LIMIT
     BOAT  CONSTITUENTS
                                   UNTREATED K046
       Metals

 154 Antimony
 155 Arsenic
 156 Barium
 157 Beryllium
 158 Cadmium
 159 Chromium
 160 Copper
 161 Lead
 162 Mercury
 163 Nickel
 164 Selenium
 165 Silver
 166 Thallium
 167 Vanadium
 168 Zinc
 0.02
 0.01
  0.2
 0.005
 0.01
 0.02
 0.025
 0.01
0.0003
 0.04
 0.005
 0.05
 0.01
 0.05
 0.05
                                 C-2

-------
TABLE  C-2 DETECTION LIMITS FOR  TREATED K046


BDAT CONSTITUENTS
Metals
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc


CEMENT

0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02
DETECTION LIMIT
(mg/l)
KILN DUST

0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02


LIME/FLYASH

0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02
                                            C-3

-------
                                APPENDIX D



                    CALCULATION OF TREATMENT STANDARDS





    This appendix shows (1) the calculation of the K046 lead treatment



standard in K046 nonwastewater and (2) the ANOVA which stabilization



binder provided the best treatment.
                                    D-l

-------
APPENDIX D   CALCULATION OF TREATMENT STANDARDS
Constituent:  Lead
1
Treated (TCLP)
Sample Set Concentration
(mg/l)
1 0.072
2 0.100
3 0.061


3 4
2 Accuracy Corrected
Percent Correction Concentration
Recovery Factor (mg/l)
77.4 1.29 0.093
77.4 1.29 0.129
77.4 1.29 0.079
x = 0.100 y
s

5
Log
Transform
-2.375
-2.048
-2.538
= -2.320
= 0.250
1 - Obtained from  the Onsite Engineering Report for K046 (Waterways Experiment  Station).
2 - Obtained from  the Onsite Engineering Report for K046 (Waterways Experiment  Station).
3 - Accuracy Correction Factor = 100 / Percent Recovery.
4 - Corrected Concentration = Effluent Concentration X Accuracy Correction Factor.
5 - Log Transform  using the natural logarithm, In,  of the Corrected Concentration.
                                                                  t
Treatment Standard = Corrected Effluent Mean X VF

Calculation of Variability Factor (VF):

C99 = exp (y + 2.33s)
      where
            y -  the mean  of the  log transforms
            s =  the standard deviation of the log transforms.

Therefore,  C99  =  exp (-2.320   0.583)
                   = exp  (-1.737)
                   = 0.176

        and  VF  =  C99 / x
      where
              x  =  the mean of the corrected effluent concentrations.

Therefore,  VF = C99 / x  .
               = 0.176 /  0.100
               = 1.76
Treatment Standard  = Corrected Effluent Mean X VF
                    = 0.100 X  1.76
                    = 0.176 mg/l
                                             D-2

-------
                DETERMINE ACCURACY  FACTORS
                                                                ANOVA FOR K046
          Component

            Lead

            Zinc

MS
'.4
96
CEMENT
MSO
77.4
98
KILN OUST
AF
1.29
1.04
MS
90.5
69
MSO
94. 5
72
AF
1.10
1.45
LIME/FLYASH
MS
69.5
67
MSO
77.2
74
AF
1.44
1.49
            II.  CORRECT AND LOG-TRANSFORM ALL DATA
                (all results are  in mg/L)
o
CO
Component       A

Lead
  Raw       0.072
  Correct   0.093
  Log      -2.375
  Log2      5.640
                              CEMENT
                                   B
                               0.100    0.062
                               0.129    0.080
                               -2.046   -2.524
                               4.188    6.373
                                                      KILN OUST
                                                    A        B
 0.900    1.100    1.000
 0.994    1.215    1.105
-0.006    0.195    0.100
 0.000    0.038    0.010
                                          LIME/FLYASH
                                        A        B
 0.400    0.400    0.400
 0.576    0.576    0.576
-0.552   -0.552   -0.552
 0.305    0.305    0.305
          Zinc
            Raw       0.036
            Correct   0.038
            Log       -3.283
            Log2      10.781
                     0.027    0.112
                     0.028    0.117
                    -3.571   -2.148
                    12.753    4.616
 0.020    0.020    0.020
 0.029    0.029    0.029
-3.541   -3.541   -3.541
12.538   12.538   12.538
 0.040    0.020   0.020
 Q.060    0.030   0.030
-2.818   -3.512   -3.512
 7.943   12.331   12.331

-------
III.  USE F-TEST TO COMPARE ALL TREATMENTS
1)  Lead
 Units
mg/l
Component
Lead
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SSB *
MSB *
SSU =
HSU =
A

0.072
0.093
-2.375
5.640
3
3
3
3
9
9.34
4.67
0.14
0.02
CEMENT
B

0.100
0.129
-2.046
4.188
number
number
number
number
number




C

0.062
0.080
-2.524
6.373
SUM



-6.946
16.201
KILN DUST
A B C SUM

0.900 1.100 1.000
0.994 1.215 1.105
-0.006 0.195 0.100 .0.289
0.000 0.038 0.010 0.048
of treatments
of data
of data
of data
of data




points for
points for
points for
points for




technology 1 (cement)
technology 2 (kiln dust)
technology 3 (1 irne/f lyash)
all technologies




                                                                                                           LIHE/FLYASH
                                                                                                         A        B
     F =   200.61

F(k-1.N-k.0.05) = F(2,6.0.05)
                                                                                                                                  SUM
                                                                                                     0.400    0.400    0.400
                                                                                                     0.576    0.576    0.576
                                                                                                    -0.552   -0.552   -0.552   -1.657
                                                                                                     0.305    0.305    0.305    0.916
                           5.14

-------
o
 I
en
2) Zinc
Units =

Component
Zinc
Raw
Correct
Log
Log2
k 
nl 
n2 =
n3 =
N =
SSB =
MSB =
SSU =
HSU =
mg/l

A

0.036
0.038
-3.283
10.781
3
3
3
3
9
0.44
0.22
1.45
0.24

CEMENT
B

0.027
0.028
-3.571
12.753
number
number
number
number
number






C SUM

0.112
0.117
-2.148 -9.003
4.616 28.149
of treatments
of data points for
of data points for
of data points for
of data points for





KILN OUST
ABC

0.020 0.020 0.020
0.029 0.029 0.029
-3.541 -3.541 -3.541
12.538 12.538 12.538

technology 1 (cement)
technology 2 (kiln dust)
technology 3 (I itne/f lyash)
all technologies






SUM



-10.623
37.615









                                                                                                                      LIME/FLYASH
                                                                                                                    A        B
                                                                                                                                             SUM
                                                                                                                0.040    0.020    0.020
                                                                                                                0.060    0.030    0.030
                                                                                                               -2.818   -3.512   -3.512   -9.841
                                                                                                                7.943   12.331   12.331   32.605
               f =
                       0.90
          F
-------
  I.  DETERMINE ACCURACY FACTORS
                                             ANOVA FOR K046 (CEMENT/KILN OUST)
Component

  Lead

  Zinc

MS
'.4
96
CEMENT
MSO
77.4
98
KILN DUST
AF
1.29
1.04
MS
90.5
69
MSO
94.5
72
AF
1.10
1.45
LIME/FLTASH
MS
69.5
67
MSO
77.2
74
AF
1.44
1.49
 II.  CORRECT AND LOG-TRANSFORM ALL DATA
      (all results are in mg/L)

Component
O
CT> Lcad
Raw
Correct
Log
Log2
Zinc
Raw
Correct
Log
Log2

A

0.072
0.093
-2.375
5.640

0.036
0.038
-3.283
10.781
CEMENT
B

0.100
0.129
-2.046
4.188

0.027
0.028
-3.571
12.753
KILN DUST
C

0.062
0.080
-2.524
6.373

0.112
0.117
-2.148
4.616
A

0.900
0.994
-0.006
0.000

0.020
0.029
-3.541
12.538
B

1.100
1.215
0.195
0.038

0.020
0.029
-3.541
12.538
C

1.000
1.105
0.100
0.010

0.020
0.029
-3.541
12.538
                                                                                          LIME/FLYASH
                                                                                        A        B
                                                                                    0.400    0.400    0.400
                                                                                    0.576    0.576    0.576
                                                                                   -0.552   -0.552    -0.552
                                                                                    0.305    0.305    0.305
                                                                                    0.040     0.020    0.020
                                                                                    0.060     0.030    0.030
                                                                                   -2.818    -3.512    -3.512
                                                                                    7.943    12.331    12.331

-------
          111.  USE F-TEST TO COMPARE TWO TREATMENTS
O
          1)  Lead
           Units =     mg/l
          Component       A

          Lead
            Raw       0.072
            Correct   0.093
            Log      -2.375
Log2

   k =
  n1 =
  n2 =
  n3 =
   N =

 SSB =
 MSB =
                       8.72
                       8.72
                              CEMENT
                                   B
                   0.100
                   0.129
                  -2.046
                                       SUM
              0.062
              0.080
             -2.524   -6.946
                      5.640    4.188    6.373   16.201
                                                             KILN OUST
                                                           A        8
 0.900    1.100
 0.994    1.215
-0.006    0.195
 0.000    0.038
2    number of treatments
3    number of data points for technology 1 (cement)
3    number of data points for technology 2 (kiln dust)
0    number of data points for technology 3 (lime/flyash)
6    number of data points for all technologies
                                                                                    SUM
1.000
1.105
0.100    0.289
0.010    0.048
             SSU
             HSU
           0.14
           0.03
               F =   249.72

          F(k-1,N-k,0.05) = F(1.4,0.05) =
                                      7.71

-------
O
 i
CO
2) Zinc
Units =

Component
Zinc
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SS8 =
MSB =
SSU =
MSU =
mg/l

A

0.036
0.038
-3.283
10.781
2
3
3
0
6
0.44
0.44
1.13
0.28

CEMENT
B

0.027
0.028
-3.571
12.753
number
number
number
number
number






C SUM

0.112
0.117
-2.148 -9.003
4.616 28.149
of treatments
of data points for
of data points for
of data points for
of data points for





KILN OUST
A 8 C

0.020 0.020 0.020
0.029 0.029 0.029
-3.541 -3.541 -3.541
12.538 12.538 12.538

technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies






SUM



-10.623
37.615









               F =     1.55



          F(k-1.N-k,0.05> - FC1.4.0.05)
7.71

-------
                                             ANOVA FOR K046 (CEMENT/LIME)
  I.  DETERMINE ACCURACY FACTORS

                    CEHENT
Component      MS      USD       AF

  Lead       77.4     77.4     1.29

  Zinc         96       98     1.04
     KILN DUST
  MS      MSD
                    AF
90.5     94.5     1.10

  69       72     1.45
     LIME/FLYASH
  MS      MSD       AF
69.5

  67
77.2

  74
1.44

1.49
 II.  CORRECT AND LOG-TRANSFORM ALL DATA
      (all results are in mg/L)

Component
Lead
Raw
Correct
Log
Log2
Zinc
Raw
Correct
Log
Log2

A

0.072
0.093
-2.375
5.640

0.036
0.038
-3.283
10.781
CEMENT
B

0.100
0.129
-2.046
4.188

0.027
0.028
-3.571
12.753

C

0.062
0.080
-2.524
6.373

0.112
0.117
-2.148
4.616
                                                      KILN DUST
                                                    A        B
                                                0.900    1.100    1.000
                                                0.994    1.215    1.105
                                               -0.006    0.195    0.100
                                                0.000    0.038    0.010
                                                0.020    0.020    0.020
                                                0.029    0.029    0.029
                                               -3.541   -3.541   -3.541
                                               12.538   12.538   12.538
                                         LIME/FLYASH
                                       A        B
                                   0.400    0.400    0.400
                                   0.576    0.576    0.576
                                  -0.552   -0.552   -0.552
                                   0.305    0.305    0.305
                                   0.040    0.020    0.020
                                   0.060    0.030    0.030
                                  -2.818   -3.512   -3.512
                                   7.943   12.331   12.331

-------
           III.   USE F-TEST  TO COMPARE  TWO TREATMENTS (CEMENT  AND LIHE/FLYASH)
O

H-'
O
           1)   Lead
            Units =
                        mg/l
Component
Lead
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSU =
A
0.072
0.093
-2.375
5.640
2
3
0
3
6
4.66
4.66
0.12
0.03
CEMENT LIME/FLYASH
B C SUM A 6 C SUM
0.100 0.062 0.400 0.400 0.400
0.129 0.080 0.576 0.576 0.576
-2.046 -2.524 -6.946 -0.552 -0.552 -0.552 -1.657
4.188 6.373 16.201 0.305 0.305 0.305 0.916
number of treatments
number of data points for technology 1 (cement)
number of data points for technology 2 (kiln dust)
number of data points for technology 3 (lime/f lyash)
number of data points for all technologies




                F  =    155.90


           F(k-1.N-k.0.05)  = F{1.4.0.05)  =
7.71

-------
o
 I
2) Zinc
Units =

Component
Zinc
Raw
Correct
Log
Log2
k =
n1 
n2 -
n3 =
N =
SSB =
MSB =
SSU 
HSU =
mg/l

A

0.036
0.03B
-3.283
10.781
2
3
0
3
6
0.12
0.12
1.45
0.36

CEMENT
B

0.027
0.028
-3.571
12.753
number
nuitoer
number
number
number






C SUM

0.112
0.117
2.148 -9.003
4.616 28. 149
of treatments
of data points for
of data points for
of data points for
of data points for





LIME/FLYASH
ABC

0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331

technology 1 (cement)
technology 2 (kiln dust)
technology 3 (1 Irne/f lyash)
all technologies






SUM



-9.841
32.605









               F =     0.32




          F(k-1.N-k,0.05) = F(1,4.0.05) =
7.71

-------
                                                       ANOVA FOR K046 (KILN OUST/LIME)
             1.  DETERMINE ACCURACY  FACTORS

Component
Lead
Zinc

MS
77.4
96
CEMENT
USD
77.4
98
KILN DUST
AF
1.29
1.04
HS
90.5
69
NSD
94.5
72
AF
1.10
1.45
LIME/FLYASH
HS
69.5
67
MSD
77.2
74
AF
1.44
1.49
            II.  CORRECT AND LOG-TRANSFORM ALL DATA
                (all results are  in mg/L)
o
 i
Component       A

Lead
  Raw       0.072
  Correct   0.093
  Log      -2.375
  Log2      5.640
                              CEMENT
                                   B
                               0.100    0.062
                               0.129    0.080
                              -2.046   -2.524
                               4.188    6.373
       KILN DUST
     A        B
 0.900    1.100    1.000
 0.994    1.215    1.105
-0.006    0.195    0.100
 0.000    0.038    0.010
       LIME/FLYASH
     A        B
 0.400    0.400    0.400
 0.576    0.576    0.576
-0.552   -0.552   -0.552
 0.305    0.305    0.305
          Zinc
            Raw       0.036
            Correct   0.038
            Log      -3.283
            Log2     10.781
                     0.027    0.112
                     0.028    0.117
                    -3.571   -2.148
                    12.753    4.616
 0.020    0.020    0.020
 0.029    0.029    0.029
-3.541   -3.541   -3.541
12.538   12.538   12.538
 0.040    0.020    0.020
 0.060    0.030    0.030
-2.818   -3.512   -3.512
 7.943   12.331   12.331

-------
           III.  USE  F-TEST TO COMPARE TWO TREATMENTS  (KILN DUST AND LIME/FLYASH)
           1)   Lead
           Units  *
                       mg/1
 I
t
GO
Component
Lead
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N -
SSB =
MSB =
SSU =
HSU -
KILN DUST
A B
0.900
0.994
-0.006
0.000
2
0
3
3
6
0.63
0.63
0.02
0.01
1.100
1.215
0.195
0.038
number
number
number
number
number




C SUM
1.000
1.105
0.100 0.289
0.010 0.048
of treatments
of data points for
of data points for
of data points for
of data points for




LIME/FLYASH
A B C SUM
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552 -1.657
0.305 0.305 0.305 0.916

technology 1 (cement)
technology 2 (kiln dust)
technology 3 (I irne/f lyash)
all technologies




                F =    125.38
          F(k-1,N-k.0.05) = F(1,4.0.05) =
7.71

-------
2) Zinc
Units =
mg/l


KILN OUST
Component
Zinc
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
HSU =
A

0.020
0.029
-3.541
12.538
2
0
3
3
6
0.10
0.10
0.32
0.08
B

0.020
0.029
-3.541
12.538
number
number
number
number
number




C SUM

0.020
0.029
-3.541 -10.623
12.538 37.615
of treatments
of data points for
of data points for
of data points for
of data points for





LIME/FLYASH
ABC

0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331

technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies






SUM



-9.841
32.605









     F =     1.27





F(k-1.N-k,0.05) * W.4.0.05)
7.71

-------
                 DETERMINATION OF SIGNIFICANT  TREATMENT
 I.   DETERMINE ACCURACY FACTORS
        Component

          Lead

          Zinc
                    CEMENT
               MS      MSD
                                                           AF
             77.4      77.4      1.29

               96        98      1.04
II.   CORRECT AND LOG-TRANSFORM ALL DATA
     (all results are in mg/l)
        Component

        Lead
          Raw
          Correct
          Log
          Log2

        Zinc
          Raw
          Correct
          Log
          Log2
UNTREATED
  TCLP
     103
 133.075
   4.891
  23.921
   0.335
   0.349
  -1.053
   1.108
 0.072
 0.093
-2.375
 5.640
                                                       CEMENT
                                                            B
 0.100
 0.129
-2.046
 4.188
 0.061
 0.079
-2.541
 6.455
 0.036    0.027    0.112
 0.038    0.028    0.117
-3.283   -3.571   -2.148
10.781   12.753    4.616
                                               D-15

-------
III.   USE F-TEST TO COMPARE UNTREATED AND TREATED WASTE (FOR CEMENT BINDER)

         1)  Lead
          Units =
         Component

         Lead
           Raw
           Correct
           Log
           Log2

              k =
             nl =
             n2 =
             n3 =
              N =

            SSB =
            MSB =

            SSU =
            MSU =

              F =
103.000
133.075
  4.891
 23.921
                                        mg/l
               2
               1
               3
               0
               4

           39.01
           39.01

            0.13
            0.06

          616.31
                                     CEMENT
                                          C
                                                 SUM
 0.072    0.100    0.061
 0.093    0.129    0.079
-2.375   -2.046   -2.541    -6.962
 5.640    4.188    6.455    16.283

 number of treatments
 number of data points  for  technology 1  (untreated)
 number of data points  for  technology 2  (treated)
 number of data points  for  technology 3
 number of data points  for  all  technologies
         F(k-1,N-k,0.05) = F(1,2,0.05) =
                                       18.5
                                                 D-16

-------
2)  Zinc
 Units
                               mg/l
Convenient
                                   CEMENT
                                        C
                                               SUM
Zinc
  Raw
  Correct
  log
  Lofl2

     k =
    n1 =
    n2 =
    n3 =
     N =

   SSB =
   MSB =
 0.335            0.036    0.027    0.112
 0.349            0.038    0.028    0.117
-1.053            -3.283   -3.571   -2.U8   -9.003
 1.108            10.781   12.753    4.616   28.149

              2    number of treatments
              1    number of data points for technology  1 (untreated)
              3    number of data points for technology  2 (treated)
              0    number of data points for technology  3
              4    number of data points for all  technologies

           2.85
           2.85
   SSU =
   NSU =
           1.13
           0.57
                               5.03
F(k-1,H-k.0.05)  F<1,2,0.05)
                                     18.5
                                       '  D-17

-------
                         APPENDIX E
       DETERMINATION OF NONREACTIVE AND REACTIVE FORMS OF K046
         UNITED STATES ENVlRONMcN . AL PROTECT,jN AGENCY

                     OFFICE OF SOLID WASTE

U.S. Army  Procedures to Determine Reactivity          "~p -> ,
                                                           *~ '  /Q;

David  Friedman,  Manager  j^^-^vus-aLrvourJ
Waste-  Analysis Program, WCB, HIWD  (V.H-565)

Betty  Willis,  Region IV
Hazardc-s  Waste  Section
     We  have  reviewed the test plan submitted by the  U.S.
Army Toxic  and  Hazardous Materials Agency lor determining
reactivity  due  to explosive "roperties.  Negative results
in the battery  of tests outlined in their pJan would  be
adequate  proof  that the soil sample is indeed not a
reactive  waste.   OSW supports the ur-- of this -..est- plan
and plans to  recommend it for use bj other generators
facing such a probl'-.n.

     If  you need  any assistance in eval'' ting, the data gen-
erated during this study, please contact Florence Richardson
cf nv staff.  She can be reached at 755-9187.
                             E-l

-------
                                          PROJECTION AGB^CY

                                       REGION IV

                                A&ffO  Informal MQTD
tfc*i  feptaober 15, 1981
*" .        ^
        avid FrieAnan,  (H
         S. ^ Anay Procedures to Determine Reactivity
'"  70:  David FrieAnan,  (HH-565)
        Pleaae review this and give me a  call at FTS 257-3433 concerning

        bow to handle this request.
            /
        Bafctv C., Willis
        EPA, legion IV
                                       E-2

-------
           *    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
          1& 0 1  198)       Region IV - Atlanta,  GA
   JK* .^Ji. ....
   '&"'**% ~' 
   F:7V   Vr  Amy  Toxic & Hazardous Materials Agency
         Dr.ikft Procedures to  Determine Reactivity

         Arthur 0 Linton
              rar Activities Coordinator
                                                              FrW/?7/v
         Janes H.  Finger,  Director
         surveillance & Analysis  Division
         /Ja&es B.  Scarbrough,  Chief
         Residuals Management  Branch
fa
.IV
        U.  S.  Army Toxic and Hazardous Materials Agency has
               that we review the three enclosures.  The purpose
    ,o|.*~'this procedure is to delineate the necessary tests,
   / frfbociated methods, and interpretation of results to
   .determine  whether contaminated soil and sediments are
  'x classified as reactive, due to their explosive properties.
$?VJrtus' information is necessary to determine what, if any,
V Jirpcessing is required for final disposal of such soil

           e  facility this procedure has been developed for is
                Army Ammunition Plant,  Milan, Tennessee.  There are
         eleven lagoons located at this facility that have been used
         tp process waters containing nitrobodies;  specifically,
         what is classified as pink water.   The closing out of these
         lagoons has a high priority within the Army and EPA
         because groundwater has been contaminated within the arsenal
         boundaries.  There is an immediate need to develop a strategy
         tp plose out these lagoons, either by filling or treating the
         sediments.
           ~M
         Feel free to contact Mr. Robert A. Breschi, who is referred
           j*in the enclosed documents.  Once your review has been
           pleted, we need to develop a mutual time during which
         ^3 Can discuss this procedure with Mr. Breschi and other
         representatives of the u. S. Army Toxic and Hazardous
         " "   '   Agency.

                    sting that you respond to my request by
                    11, 1981.  I am targeting a meeting with the
                   .. Toxic and Hazardous Materials Agency during
                   of September 21.
 r,**--*
                                   E-3

-------
                     DEPARTMENT OF THE ARMY


                 US AIWY TOXIC AMD HAZARDOUS *UIAUS

                                         1KHO
 Hr. Art Llnton              .^_ _.-.
 Federal Activities Coordinator  (Rm 203)
 Efjylroiwental Protection Agency

 34$ Courtland Street
 Atlanta, Georgia 30365
  Dear Hr. Llnton:



-geS^'5'HffSSSMSsr'

'situated at Milan AAP.                                         J.

"1m.m 1 .< 2 . copies of t^e r!jus  deterge ^cjnt^

  ^v?rP^sl?^rtU?r.SUheiflCSi"UrnA.dint . ,o f.ct

  reactive.
                           * /-r\i\ t?i ??70  Also notify roe when the EPA
  If thtre are questions call me at (301) ^1-2270. j;s5.;cus/the proceoufe5.
  review process 1s complete so a meeting can oe sei v> u


 ..- | appreciate your attention to this matter.

 " -*'                             Sincerely.



                                 ?J(A  ,'J^^l i^

   .  t  .                         ROBERT A.  BRESCW
   3 Inci                         Environmental  Engineer
   As stated                      us Anny Toxic  and Hazardous
  '   :-                           Materials Agency
                                  E-4

-------
                   TEST PLAN TO DETERMINE REACTIVITY OF
               EXPLOSIVELY CONTAMINATED SOIL AND SEDIMENT*
I.     PURPOSE

The  purpose of  this plan is  to delineate the necessary tests,  associated methods, and
interpretation of  results to  determine  whether  a  contaminated soil  of  sediment  is
classified as reactive due to its explosive  properties.  Such  information  is necessary  to
determine what (if  any) processing is  required prior to final  disposal of such soil  or
sediment.
II.    REFERENCE

              a. Title 40 Code of Federal Regulations, Part 261, Para 261.23,
                Characteristic of Reactivity.

         b. EPA  Publication  SW  846,  Test   Method   for  Evaluating  Solid  Waste.
           Subsection) 6-2; Definition of Explosive Materials (attached as Incl. 1).

         c. Army Technical Bulletin 700-2, Chapter 3:     Minimum Test Criteria for Bulk
           Explosive Compositions and Solid Propellant Compositions.

         d. FONECONS with  Dr.  H.  Matsuguma,  Chief,  Chemistry Branch, Energetic
           Materials Division, Large  Caliber  Weapons  System  Laboratory,  U.S. Army
           Armament Research and Development Command, SAB.
III.   BACKGROUND

Due to explosives production, employment, and disposal operations performed through the
years at various military installations across the country, the Army owns  property which
contains potentially explosively contaminated soils and sediments.  Efforts are underway
to  begin  decontamination  and  close-out  of  such  sites  in  compliance  with  Federal
Environmental  Regulations.  Explosives, however, are governed by Ref. 2a, which restricts
reactive  materials  from begin  landfilled,  including placement in a  hazardous  waste
landfill.   By regulation,  then, every Army site which contains explosive residues, which
range from  low parts per million up to fifty percent  in  the  worst cases, would require
treatment  prior to final disposal.  Since  many sites with low levels of contamination are
not expected to exhibit  any explosive properties, identifying such sites would remove
from them the  requirement  to treat  the residues as reactive wastes.  Therefore, tests are
provided in this plan which are suitable for determining whether a contaminated soil or.
sediment  is reactive due  to explosivity according to Environmental Protection  Agency
definitions.
     *Thrce sediment samples are obtained  from each lagoon and analyzed for explosive
     concentration.  One sample is  taken  near  the  waste  water influent  point,  another
     near  the  effluent  point,  and  the third sample  is taken  from the  middle  of  the
     lagoon.


                                   E-5

-------
a. Of  the  eight characteristics defining  a  reactive  waste  in  Rcf.  2a,  the
  characteristics pertaining to explosive wastes arc:

  1.    Capable  of detonation  or  explosive reaction  if  subjected  to a  strong
        initiating source or if heated under confinement.

  2.    Capable of detonation or explosive decomposition or reaction at standard
        temperature or pressure.

  3.    Is  a  forbidden explosive as defined  in 49  CFR  173.51  or a  Class A or
        Class B  explosive as defined in 49 CFR 173-53 and  88.

b. Ref.  2b  defined  tests for explosives  which address the above  definitions of
  reactivity  as follows:

  1.    A  Stability Test  is  performed  by  heating  the  residue  to  75CC  for
        48 hours.   This  test defines  a  forbidden  explosive  according  to  49
        CFR 173.51.

  2.    A  Detonation Test is performed by  inserting a blasting  cap into a sample
        and  observing  the detonation.   Reaction  of the  sample  to  a  strong
        initiating source and Class  A explosives as defined in 49 CFR  173.53 are
        tested in this manner.

  3.    A  Spark Test is performed by inserting a time fuze or an electric squib
        into  a sample  and observing for deflagration or detonation.  This tests
        for explosives as defined  in 49  CFR 173.53  (initiating explosives)  and
        49 CFR 173.88 (propellants).

  4.    An  Impact  Test is  performed  on   the  Bureau  of Explosives  Impact
        Apparatus to define Class A explosives according to 49  CFR  173.5J.

c. In  Ref.  2d,  the  above tests  were discussed with  Dr.  H. Matsuguma  of  the
  Army's  Primary  Explosives  Research   Laboratory.    Pertinent  comments
  regarding the above  tests  were as follows:

  1.    The  tests are  adequate  for a go/no-go evaluation of  reactivity, except
        that  the  results of the Impact Tests will be misleading  at low explosive
        concentrations. Since impact testing  is designed to be a severe test used
        for ranking reactions of various explosives.   It  is possible  to  eke  out
        positive   results   even   from   minute   quantities   of   explosives.
        Supplementing Impact Test results with a Card Gap Test,  as outlined in
        Ref.  2c, will  better  define  the ability  of a contaminated  sample to
        propagate detonation.

  2.    Soil and  sediment samples should be analyzed  to determine the explosive
        constituents and their concentrations.  However, the chemical  analysis
        methods  are  not germane  to  the  actual  reactivity tests  and  are  not
        addressed in this plan.
                             E-6

-------
           3.     The Stability, Detonation, Impact, and Card Gap Tests are performed in
                 a  standard  manner, although some minor  modifications are required to
                 accommodate preparation  of environmental  samples.  The  Spark  Test  is
                 not  a  standard  test  for the  Army,  but  with  modification, can  be
                 performed in the same manner as the Detonation Test.
V.    TEST EQUIPMENT AND MATERIALS

The  following items are required to perform the necessary explosives tests on one field
sample. Ancillary laboratory equipment is not included.

         a. One  Bureau of Explosives Impact Apparatus.

         b. One   ventilated   explosion-proof  oven   equipped  to  continuously  record
           temperature.

         c. One  blasting machine or equivalent.

         d. Electric firing wire.

         e. Electric blasting caps.

           1.     Five  No. 8  electric  blasting caps  (contains 2  gms  of  80/20  mixture
                 mercury fulminate/potassium chlorate).

           2.     Three engineer special electric blasting caps.

         f. Five electric match head  igniters.

         g. Two  inch  diameter  by 1 inch long  pressed pentolite  pellet,  National Stock
           No. 1375-00-991-8891, as required.

         h. Solid lead cylinders 1-1/2 inch diameter by 4 inches high as required.

         f. One  piece of mild steel plate  SAE  1010  to  1030, 1/2 inch thick by  12 inches
           square.

         j. Mild steel plates (SAE  1010 to  1030) 6x6 inches x 3/8 inch as required.

         k. Tubing, steel cold drawn seamless, mechanical, composition 1015, 1-7/8 inch
           00, 0.219 inch  wall thickness by 5-1/2  inch long, as required.
VI.  SAMPLE PREPARATION:

A  complete set of tests will require  a  five pound sample from each field  sampling point.
Samples  will  generally be received  wet and possibly split  into  multiple containers for
shipping purposes.  The field sample will be  prepared and  split into laboratory samples as
follows:

         a. Recombine samples if necessary.  Samples may  be mixed while wet to achieve
           uniformity. Large  chunks should be broken up,  in a  ball  mill or mortar and
           pestle, using an operational shield if necessary.
                                      E-7

-------
         b. The wet samples must be dried to the appropriate moisture content for testing.

           1.    The apropriate  moisture  content  will  be  determined  by taking a soil
                sample  from a depth of four feet at  a point  close to the  lagoon  being
                sampled.   That sample will then  be  weighed, dried  in an  oven until
                constant  weight  is achieved,  and then  reweighcd.    From  this,  the
                moisture content will be calculated.

           2.    For  each soil or sediment  sample to  be tested  for  explosivity,  a  sub-
                sample  will  be drawn, weighed,  oven dried,  and then reweighed  to
                determine  its original moisture  content.  The amount of water  weight
                which must be removed from each sample  to reach the moisture content
                in 6b(l) above will  then be calculated.

           3.    Each soil  or sediment  sample  will then be weighed, spread  in  a  thin
                layer on a tray, and then dried  in an  oven at  60  C until the amount  of
                water weight  calculated in  6b(2) above has been  removed.  The sample
                must be monitored  and  reweighcd  until the desired weight is reached.

         c. Laboratory test  samples  will be prepared from  the  prepared field  sample  as
           follows:

           1.    For  the  Thermal  Stability, Detonation, and Spark Tests,  prepare a total
                of eleven samples by filling a  four-ounce  paper cup  approximately 2/3
                full.  The sample should not contain large  chunks and should be tamped
                as it is  filled to insure continuity of the sample.

           2.    For  the Impact Sensitivity Test, withdraw an approximate 200 m|> sample
                from the field sample.  This sample must then be carefully crushed  so
                that  10 mg of  uniformly  fine  consistency  can be drawn  from  it.
                Description of the  individual samples  is incorporated under  the Impact
                Sensitivity Test.

           3.    For  the Card Gap Test, prepare  three  samples  by  filling the tubes listed
                in para. 5k with the material  to be tested.  Insure  that the sample is
                continuous by tamping.  If  the consistency of  the sample is such that it
                will not consolidate, a piece of  light cellophane tape may  be  placed
                across the lower end to  retain the sample.
VII.  TEST METHODS

Although  it could be argued that some of  these tests are not applicable to certain  pure
explosives, it is  possible  to encounter residues  from mixed explosives or  environmentally
altered  residues  which will not behave in  the classic manner.   Therefore,  the  complete
series of tests will be performed on each sample.  Test results will be recorded  on a  data
sheet similar  to Fig.  1. Tests may be run in  any convenient order.

         a. Thermal   Stability.    Place  one sample  from  para.  6d(l)  in  a  constant
           temperature explosion-proof  oven.  Raise temperature of the oven to 75C and
           maintain at 75C for 48 consecutive hours. Temperatures will be continuously
           recorded.  Constant  observation is not required. Record results on data sheet.


                                         E-8

-------
b. Spark Test. Place a lead  block (para.  5h) on the steel plate (para. 5i).  Using a
  sample  from para. 6d(l),  make a small depression in  the sample  with stick or
  pencil,  insert an  electric match head igniter (para. 5f) into the depression  and
  secure (tape) the igniter wires to the  cup for  stability.  Place the  cup on the
  lead block, connect the firing circuit,  and remotely initiate.  Deflagration  will
  be  evidenced  by the  energetic  burning of the  sample.   Detonation  of  the
  sample  will cause mushrooming of the lead  block.  Repeat the test  five times
  or  until evidence of  a deflagration  or detonation occurs, whichever  is  less.
  Record  results on data sheet.

c. Detonation Test.  Place a lead  block (para. 5h)  on  the steel plate (para. 5i).
  Using a sample  from  para.  6d(l),  press a hole about half the length  of the
  blasting cap into the center  of the sample  using  a pencil,  then insert ji No. 8
  blasting cap into the sample.  A wood  block  with  a hole drilled in it similar to
  Fig. 2 may be used to  support the blasting cap.  Place the sample  onto the  lead
  block,  connect the firing circuit,  and  remotely  initiate.  Detonation  of the
  sample  will cause mushrooming of the lead  block.  Repeat the test  five times
  or until detonation occurs, whichever  is  less. Record results on a  data sheet.

d. Impact  Sensitivity Test:  Conduct ten  individual  tests using  one  sample (para.
  6d(2)) per  test in the Bureau of  Explosives Impact'Apparatus. Place a  10 mg
  sample  in the cup assembly.  Drop  the weight from the maximum heighl: of the
  machine.  Observe the result and record  on  the data sheet.  Conduct tesi:s at an
  ambient temperature  of  25C  5C.   Insure  cup and anvil  are  thoroughly
  cleaned and dried between test runs.

e. Gap Test

  1.     Assemble the following items for each  test to be conducted:

        a.    One  sample prepared  according to para. 6d(3).

        b.    Two pentolite pellets  (para. 5g).

        c.    One  engineer's special electric blasting cap, J2 (para. 5e(2)).

        d.    Blasting machine and firing wire (para 5c. and d).

        e.    One  5x6 inch steel plate (para. 5j).

        f.    Plastic material,  1/16 inch  thick cut into  1/2 inch squares.

  2.    Arrange the materials as shown  in  Fig. 2.  The  witness  plate is supported
       on two edges,  about 6 inches above ground surface.   The small  plastic
       squares are placed on the plate  to  support the pipe and maintain  a 1/16
        inch  air gap. The squares  should  be  under the edge of the pipe,  rather
        than  under the explosive.  The pentolite  boosters are then placed  on top
       of the  sample as shown in  Fig. 2, except  that the  gap cards and  the
       cardboard  tube  are  not used.  The blasting  cap  is then placed on top of
        the  pentolite  (with a wood support  ring) and remotely   detonated.
        Detonation of the sample is  indicated when a  clean hole  is cu1; in  the
       witness plate.  This test is  performed  three times or until  a  detonation
       occurs, whichever is less. Results are recorded on the data sheet.


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VIII.  INTERPRETATION OF RESULTS

For  the purpose  of reactivity evaluation,  a  positive result  from  any single test  will
indicate that a given field sample is reactive, except that results from the Impact and  Gap
Tests should be considered together.

         a.  A sample is considered reactive  due to instability if it detonates, deflagrates,
            or  decomposes exothermically (as evidenced by a rise in temperature on  the
            recorder) during  the Thermal Stability Test.

         b.  The field  sample  is  considered  to  be  reactive if  one lab  sample  deionates,
            deflagrates, or burns in a sustained flame  during  the Spark Test.  Localized
            smoldering does not indicate reactivity.

         c.  The field  sample  is  reactive if  one  sample detonates during the  detonation
            test.

         d.  The  Impact  Sensitivity  Test   may  be  considered  positive  if   detonation
            (explosion,  flame, noise)  occurs in  at  least  50  percent of  the  ten  tests.
            Conversely, if detonation does not occur in  at least 50 percent of the tests, the
            sample is non-reactive.  However, the  results of the  Impact Sensitivity  Test are
            the  most difficult to  interpret, since  samples can  exhibit  partial  response
            under such  harsh treatment.  In  such  cases, the Gap Test  should be used  as a
            discriminator, defining a  material as reactive if it detonates once out  of  three
            tests.
IX.   CONCLUSION
The  tests  conducted  under  this plan  exceed  minimum  requirements  for  determining
reactivity  due to explosive  properties as specified  in  Ref. 2b.   The  Thermal  Stability,
Spark, and  Detonation Tests  are performed as specified.  The Impact  Sensitivity Test is
performed in  a manner more  stringent than specified to insure that results are safe-sided.
Since Impact  Sensitivity  Tests  may  present results  which are difficult  to interpret,  the
Shock or Gap Test has been added  as a discriminator to determine  whether a  questionable
material is detonable  under worst-case conditions.  It can  be stated with certainty  that a
sample  which does not respond positively  to  these  tests is not reactive  due  to  explosive
properties as defined in Ref. 2a.
                                       E-10

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                                 SW 84B, DATED MAY 1980
                   "TEST METHODS FOR EVALUATING SOLID WASTE"

                                     SUBSECTION 6.2

                         DEFINITION OF EXPLOSIVE MATERIALS

      For  purposes of this regulation, a waste which is a reactive waste by reason of cxplosivity
      is one which meets one or more of the following descriptions:

      1.   Is  explosive  and  ignites  spontaneously or undergoes  marked decomposition  when
          subjected for 48 consecutive hours to a temperature of 75C (167F).

      2.   Firecrackers, flash crackers, salutes, or similar commercial devices which  produce  or
          are intended  to produce an audible effect, the explosive content of which exceeds  12
          grains each in weight, and pest control bombs, the explosive content of which exceeds
          18 grains each  in weight;  and any such devices, without respect to explosive content,
          which on  functioning are  liable  to project  or disperse  metal,  glass  or brittle  plastic
          fragments.

      3.   Fireworks that combine  an explosive and a detonator or blasting cap.

      4.   Fireworks containing an ammonium salt and a chlorate.

      5.   Fireworks containing yellow or  white phosphorus.

6.     Fireworks  or  fireworks  compositions  that  ignite   spontaneously  or undergo  marked
      decomposition when subjected for 48 consecutive hours to a temperature of 75C (167F).

7.     Toy  torpedoes, the maximum outside dimension of which exceeds 7/8 inch, or toy torpedoes
      containing a mixture  of potassium  chlorate,  black antimony and sulfur with  in  average
      weight  of explosive composition in each torpedo exceeding four grains.

8.     Toy  torpedoes  containing a  cap composed of a mixture of red phosphorus  and potassium
      chlorate exceeding an average of one-half (0.5) grain per cap.

      9.   Fireworks containing copper sulfate and a chlorate.

10.    Solid materials which  can  be caused to deflagrate by contact  with sparks or flame such  as
      produced by safety fuse or  an electric squib, but can  not  be  detonated  (see  Note  1) by
      means  of  a  No.  8  test blasting  cap (see  Note 2).   Example:   Black powder  and low
      explosives.

11.    Solid materials which  contain  a liquid ingredient, and which, when unconfined (see Note
      3), can  be  detonated by means of a No. 8 test blasting cap (see  Note 2); or which can  be
      exploded in at least 50 percent of the  trials in the Bureau of Explosives' Impact Apparatus
      (see  Note 4)  under a drop  of 4 inches or more, but can not be exploded in more than  50
      percent  of the  trials  under a  drop of less  than  4  inches.   Example:  High  explosives,
      commercial dynamite  containing a  liquid  explosive ingredient, primarily  nitroglycerin
      component.
                                         E-ll

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12.    Solid  materials which contain no  liquid  ingredient and which  can be  detonated, when
      unconfincd (see Note 3), by means  of No. 8 test blasting  cap (see  Note 2); or which can be
      exploded in at least 50 percent of the trials in  the Bureau of Explosives' Impact Apparatus
      (see Note 4) under a  drop of 4 inches or more, but can  not be exploded in  more than 50
      percent  of  the trials  under a drop of less  than  4 inches.   Example:   High  explosives,
      commercial dynamite  containing no liquid  explosive  ingredient, trinitrotoluene, amatol,
      tctryl, picric acid, ureanitrate, pentolite, commercial boosters.

13.    Solid materials which can be caused to detonate when unconfincd (see Note  3), by contact
      with sparks or flame  such as produced by safety  fuse or an electric squib; or which can be
      exploded in the  Bureau of Explosives'  Impact Apparatus  (see Note 4), in  more than 50
      percent of the trials  under a drop of less than 4  inches.  Example:  Initiating and priming
      explosives, lead azide, fulminate of  mercury,  high explosives.

14.    Liquids  which may be detonated separately  or when absorbed in  sterile absorbent cotton,
      by a No. 8  test blasting cap (see  Note  2); but which can  not be exploded  in  the Bureau of
      Explosives'  Impact Apparatus (see  Note 4), by a drop  of less  than  10 inches.  The  liquid
      must  not  be  significantly  more  volatile than  nitroglycerine  and  must  not  freeze at
      temperatures above minus 10F.  Example:  High explosives, desensitized nitroglycerine.

15.    Liquids  that can  be  exploded in  the Bureau  of Explosives' Impact Apparatus (sec Note 4)
      under a  drop of less than  10 inches. Example:  Nitroglycerine.

16.    Blasting caps.   These  are  small  tubes, usually made  of an alloy  of either copper or
      aluminum, or of molded plastic closed at one end and loaded with a charge of initiating or
      priming explosives.  Blasting caps (see Note 5)  which have been provided with a means for
      firing by an electric  current, and sealed, are known as electric  blasting caps.

17.    Detonating  primers  which contain  a detonator and an  additional charge of  explosives, all
      assembled in a suitable envelope.

18.    Detonating  fuses, which are used  in the military  service  to  detonate  the  high explosive
      bursting charges  of  projectiles, mines,  bombs, torpedoes, and  grenades.   In  addition to a
      powerful detonator, they may contain  several  ounces of a high explosive, such  a tetryl or
      dry nitrocellulose, all assembled in  a heavy steel  envelope.  They  may also contain a small
      amount  of  radioactive component.   Those  that will not  cause functioning of oi:her fuses,
      explosives, or  explosive devices in  the same  or adjacent  containers are classed  ;is Class  C
      explosives and are not reactive waste.

19.    A shaped charge, consisting of a  plastic paper or  other suitable container comprising  a
      charge of not  to exceed 8  ounces of  a  high explosive containing no  liquid  explosive
      ingredient and with a hollowed-out  portion (cavity) lined  with  a rigid material.

20.    Ammunition or explosive projectiles, either fixed, semi-fixed or separate components which
      are  made for  use in  cannon,  mortar, howitzer, recoilless rifle, rocket, or other launching
      device with a caliber  of 20mm or larger.
                                          E-12

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21.    Grenades.  Grenades,  hand or rifle, are small metal or  other  containers designed  to be
      thrown by  hand or projected from a rifle.  They are  filled  with an explosive  or a liquid,
      gas, or solid material such as a tear gas or an incendiary or  smoke producing material and
      a  bursting charge.

22.    Explosive bombs.   Explosive bombs are metal  or  other containers filled with explosives.
      They are used in warfare and include airplane bombs and  depth  bombs.

23.    Explosive mines.  Explosive mines are metal  or composition containers filled  with a high
      explosive.

24.    Explosive torpedoes.  Explosive torpedoes, such  as those  used in  warfare, are metal  devices
      containing  a means of propulsion and a quantity of high explosives.

25.    Rocket  ammunition.   Rocket  ammunition  (including  guided  missiles)  is   ammunition
      designed  for  launching from a tube, launcher,  rails, trough, or  other launching device,  in
      which  the  propcllant  material  is  a solid propcllant explosive.  It consists of  an  igniter,
      rocket  motor, and  projectile (warhead) either  fused or unfuscd,  containing high explosives
      or chemicals.

26.    Chemical ammunition.   Chemical ammunition  used  in  warfare is all  kinds  of explosive
      chemical  projectiles, shells, bombs, grenades, etc., loaded with  tear, or other gas, :;moke  or
      incendiary  agent,  also  such  miscellaneous  apparatus  as   cloud-gas  cylinders,  smoke
      generators, etc.,  that may be utilized to project chemicals.

27.    Boosters,  bursters,  and supplementary charges.   Boosters  and supplementary charges consist
      of a casing containing a high explosive and are used to  increase the intensity of explosion
      of the detonator of  a detonating fuse.  Bursters consist of  a casing containing a high
      explosive and are used to rupture a projectile or bomb to permit  release of its contents.

28.    Jet  thrust  units or other rocket  motors containing a  mixture of  chemicals  capable of
      burning rapidly  and producing  considerable pressure.

29.    Propellant  mixtures (i.e.,  and chemical  mixtures which  are designed  to function by  rapid
      combustion with little  or no smoke).

      Note 1:     The  detonation test is performed  by placing the sample in an open-end  fiber
                 tube which is  set  on  the end of  a lead block approximately  1-1/2 inches  in
                 diameter and  4 inches high which,  in turn,  is placed on a solid base.  A steel
                 plate may be placed between  the fiber tube and the lead block.

      Note 2:     A No.  8 test blasting cap is one  containing  two grams of a  mixture of 80
                 percent mercury  fulminate and  20  percent potassium  chlorate, or a.  cap of
                 equivalent  strength.

      Note 3:     "Unconfined" as used  in  this  section does not exclude the use of a paper or soft
                 fiber tube wrapping to facilitate tests.
                                          E-13

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Note 4:    The Bureau of Explosives' Impact Apparatus is a testing device designed so that
           a guided 8-pound weight may be dropped from  predetermined height:; so as to
           impact specific quantities of liquid  or  solid materials  under fixed conditions.
           Detailed  prints may be obtained  from the  Bureau of Explosives, 2 Pennsylvania
           Plaza, New York, New  York  10001.

Note 5:    Blasting  caps, blasting caps  with  safety fuse,  or  electric  blasting  caps  in
           quantities of  1,000 or less are classified  as Class 0 explosives and  not subject to
           regulation as a reactive waste.
                                   E-14

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                     REACTIVITY/EXPLOSIVITY TEST DATA SHEET
     Installation
     Sample Number and Location
     Explosive Components and Concentrations
     Test Result: Sample is Reactive/Non-Rcactive (circle one)
Detonation Test
No. 8  Blasting Cap Test I
                  Test II
                  Test III
                  Test IV
                  Test V

Samples:    Five 4 oz. cups
                                  Exploded
                                  Yes    No
                              Deflagration
                              Yes     No
       Test:     One blasting cap per sample.
Spark Test
Electric Match Head Igniter
                     Test I
                     Test II
                     Test III
                     Test IV
                     Test V

Samples:    Five 4 oz. cups
                                  Exploded
                                  Yes   No
                                Burned
                              Yes     No
Thermal Stability Test
                                  Explosion
                                  Yes    No
             Ignition
             Yes  No
    Marked
   Decomposition
   Yes    No
Samples:    One 4 oz. cups
       Test:     48 hours at 75C in vented oven.
Card Gap Test Samples:    3 Tubes
Detonation:      Yes
No
                                      E-15

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Impact Sensitivity Test
Bureau of Explosives Impact Apparatus

Maximum Height        Drop Test
                10  Trials

   No. of Trials Exhibiting
                                         Explosion
                                         Flame and
                                         Noise
                No Explosion
                No Flame
                No noise
Approved:

    Test Director
       Test Department Head

       Signature 	

       Title
                                                Organization
                                       E-16

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   Wood BUe*
   Ptntolite Booster
   Crd Cp Ctllulect
   Act*t  Crdt
   0,01 inch etch
  fropH*nt or
  Cpletvt Competi-
  tion S**pl
  Crdbord Tub*
  1/16 inch air gap between
  Sttl Tub* *nd PUtt
 Wood Stand
  3/8 Incb
  Vltntts ?Ut*
Croum*
                         t. 5*IMP
                                                                  AGO T1AA
                              E-17

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