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
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7-1
7-1
7-2
7-3
7-5
8-1
9-1
A-l
B-l
C-l
D-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 103-105°C) 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
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of sampling, the constituents to be analyzed and the method of analysis,
operational parameters to be obtained, and specific laboratory quality
control checks on the analytical results.
The Agency will generally produce a draft of the site-specific SAP
within 2 to 3 weeks of the engineering visit. The draft of the SAP is
then sent to the plant for review and comment. With few exceptions, the
draft SAP should be a confirmation of data collection activities
discussed with the plant personnel during the engineering site visit.
EPA encourages plant personnel to recommend any modifications to the SAP
that they believe will improve the quality of the data.
It is important to note that sampling of a plant by EPA does not mean
that the data will be used in the development of BOAT treatment
standards. EPA's final decision on whether to use data from a sampled
plant depends on the actual analysis of the waste being treated and on
the operating conditions at the time of sampling. Although EPA would not
plan to sample a facility that was not ostensibly well designed and well
operated, there is no way to ensure that at the time of the sampling the
facility will not experience operating problems. Additionally, EPA
statistically compares its test data to suitable industry-provided data,
where available, in its determination of what data to use in developing
treatment standards. The methodology for comparing data is presented
later in this section.
1-15
-------
(Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA. Such facilities
should review the Generic Quality Assurance Pro.iect Plan for the Land
Disposal Restrictions Program ("BOAT"), which delineates all of the
quality control and quality assurance measures associated with sampling
and analysis. Quality assurance and quality control procedures are
summarized in Section 1.2.6 of this document.)
(4) Sampling visit. The purpose of the sampling visit is to collect
samples that characterize the performance of the treatment system and to
document the operating conditions that existed during the waste treatment
period. At a minimum, the Agency attempts to collect sufficient samples
of the untreated waste and solid and liquid treatment residuals so that
variability in the treatment process can be accounted for in the
development of the treatment standards. To the extent practicable, and
within safety constraints, EPA or its contractors collect all samples and
ensure that chain-of-custody procedures are conducted so that the
integrity of the data is maintained.
In general, the samples collected during the sampling visit will have
already been specified in the SAP. In some instances, however, EPA will
not be able to collect all planned samples because of changes in the
facility operation or plant upsets; EPA will explain any such deviations
from the SAP in its follow-up onsite engineering report.
1-16
-------
(5) Onsite engineering report. EPA summarizes all its data
collection activities and associated analytical results for testing at a
facility in a report referred to as the onsite engineering report (OER).
This report characterizes the waste(s) treated, the treated residual
concentrations, the design and operating data, and all analytical results
including methods used and accuracy results. This report also describes
any deviations from EPA's suggested analytical methods for hazardous
wastes that appear in Test Methods for Evaluating Solid Waste. SW-846,
Third Edition, November 1986.
After the OER is completed, the report is submitted to the waste
generator and/or treater for review. This review provides a final
opportunity for claiming any information contained in the report as
confidential. Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed as confidential.
1.2.4 Hazardous Constituents Considered and Selected for Regulation
(1) Development of BOAT list. The list of hazardous constituents
within the waste codes that are targeted for treatment is referred to by
the Agency as the BOAT constituent list. This list, provided as
Table 1-1, is derived from the constituents presented in 40 CFR Part 261.
Appendices VII and VIII, as well as several ignitable constituents used
as the basis of listing wastes as F003 and F005. These sources provide a
1-17
-------
1521g
Table 1-1 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
-------
There is an additional step in the calculation of the treatment
standards in those instances where the ANOVA analysis shows that more
than one technology achieves a level of performance that represents
BOAT. In such instances, the BOAT treatment standard for each
constituent of concern is calculated by first averaging the mean
performance value for each technology and then multiplying that value by
the highest variability factor among the technologies considered. This
procedure ensures that all the technologies used as the basis for the
BOAT treatment standards will achieve full compliance.
1.2.5 Compliance with Performance Standards
Usually the treatment standards reflect performance achieved by the
best demonstrated available technology (BOAT). As such, compliance with
these numerical standards requires only that the treatment level be
achieved prior to land disposal. It does not require the use of any
particular treatment technology. While dilution of the waste as a means
to comply with the standards is prohibited, wastes that are generated in
such a way as to naturally meet the standards can be land disposed
without treatment. With the exception of treatment standards that
prohibit land disposal, or that specify use of certain treatment methods.
all established treatment standards are expressed as concentration levels.
EPA is using both the total constituent concentration and the
concentration of the constituent in the TCLP extract of the treated waste
as a measure of technology performance.
1-30
-------
For all organic constituents, EPA is basing the treatment standards
on the total constituent concentration found in the treated waste. EPA
Is using this measurement because most technologies for treatment of
organics destroy or remove organics compounds. Accordingly, the best
measure of performance would be the total amount of constituent remaining
.after treatment. (NOTE: EPA's land disposal restrictions for solvent
waste codes F001-F005 (51 FR 40572) use the TCLP extract value as a
measure of performance. At the time that EPA promulgated the treatment
standards for F001-F005, useful data were not available on total
constituent concentrations in treated residuals, and, as a result, the
TCLP data were considered to be the best measure of performance.)
For all metal constituents, EPA is using both total constituent
concentration and/or the TCLP extract concentration as the basis for
treatment standards. The total constituent concentration is being used
when the technology basis includes a metal recovery operation. The
underlying principle of metal recovery is that it reduces the amount of
metal in a waste by separating the metal for recovery; total constituent
concentration in the treated residual, therefore, is an important measure
of performance for this technology. Additionally, EPA also believes that
it is important that any remaining metal in a treated residual waste not
be in a state that is easily Teachable; accordingly, EPA is also using
the TCLP extract concentration as a measure of performance. It is
important to note that for wastes for which treatment standards are based
1-31
-------
on a metal recovery process, the facility has to comply with both the
total and the TCLP extract constituent concentrations prior to land
disposing the waste.
In cases where treatment standards for metals are not based on
recovery techniques but rather on stabilization, EPA is using only the
TCLP value as a measure of performance. The Agency's rationale is that
stabilization is not meant to reduce the concentration of metal in a
waste but only to chemically minimize the ability of the metal to leach.
1.2.6 Identification of BOAT
BOAT for a waste must be the "best" of the demonstrated available
technologies. EPA determines which technology constitutes "best" after
screening the available data from each demonstrated technology, adjusting
these data for accuracy, and comparing the performance of each
demonstrated technology to that of the others. If only one technology is
identified as demonstrated, it is considered "best"; if it is available,
the technology is BOAT.
(1) Screening of treatment data. The first activity in
determining which of the treatment technologies represent treatment by
BOAT is to screen the treatment performance data from each of the
demonstrated and available technologies according to the following
criteria:
1. Design and operating data associated with the treatment data
must reflect a well-designed, well-operated system for each
treatment data point. (The specific design and operating
parameters for each demonstrated technology for the waste
code(s) of interest are discussed in Section 3.2 of this
document.)
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2. Sufficient QA/QC data must be available to determine the true
values of the data from the treated waste. This screening
criterion involves adjustment of treated data to take into
account that the true value may be different from the measured
value. This discrepancy generally is caused by other
constituents in the waste that can mask results or otherwise
interfere with the analysis of the constituent of concern.
3. The measure of performance must be consistent with EPA's
approach to evaluating treatment by type of constituents (e.g.,
total concentration data for organics, and total concentration
and TCLP extract concentration for metals from the residual).
In the absence of data needed to perform the screening analysis, EPA
will make decisions on a case-by-case basis as to whether to use the data.
as a basis for the treatment standards. The factors included in this
case-by-case analysis will be the actual treatment levels achieved, the
availability of the treatment data and their completeness (with respect
to the above criteria), and EPA's assessment of whether the untreated
waste represents the waste code of concern.
(2) Comparison of treatment data. In cases in which EPA has
treatment data from more than one demonstrated available technology
following the screening activity, EPA uses the statistical method known
as analysis of variance (ANOVA) to determine if one technology performs
significantly better than the others. This statistical method
(summarized in Appendix A) provides a measure of the differences between
two data sets. Specifically, EPA uses the analysis of variance to
determine whether BOAT represents a level of performance achieved by only
one technology or represents a level of performance achieved by more than
one (or all) of the technologies. If EPA finds that one technology
performs significantly better (i.e., is "best"), BOAT treatment standards
1-33
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are the level of performance achieved by that best technology multiplied
by the corresponding variability factor for each regulated constituent.
If the Agency finds that the levels of performance for one or more
technologies are not statistically different, EPA averages the
performance values achieved by each technology and then multiplies this
value by the largest variability factor associated with any of the
technologies.
(3) 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 constituent—minus the initial
concentration in the samples, all divided by the spike amount added) for
each spiked sample of the treated residual. Once the recovery values are
determined, the following procedures are used to select the appropriate
percent recovery value to adjust the analytical data:
1-34
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1. If duplicate spike recovery values are available for the
constituent of interest, the data are adjusted by the lowest
available percent recovery value (i.e., the value that will
yield the most conservative estimate of treatment achieved).
However, if a spike recovery value of less than 20 percent is
reported for a specific constituent, the data are not used to
set treatment standards because the Agency does not have
sufficient confidence in the reported value to set a national
standard.
2. If data are not available for a specific constituent but are
available for an isomer, then the spike recovery data are
transferred from the isomer and the data are adjusted using the
percent recovery selected according to the procedure described
in (1) above.
3. If data are not available for a specific constituent but are
available for a similar class of constituents (e.g., volatile
organics, acid-extractable semivolatiles), then spike recovery
data available for this class of constituents are transferred.
All spike recovery values greater than or equal to 20 percent
for a spike sample are averaged and the constituent
concentration is adjusted by the average recovery value. If
spiked recovery data are available for more than one sample, the
average is calculated for each sample and the data are adjusted
by using the lowest average value.
4. If matrix spike recovery data are not available for a set of
data to be used to calculate treatment standards, then matrix
spike recovery data are transferred from a waste that the Agency
believes is similar (e.g., if the data represent an ash from
incineration, then data from other incinerator ashes could be
used). While EPA recognizes that transfer of matrix spike
recovery data from a similar waste is not an exact analysis,
this is considered the best approach for adjusting the data to
account for the fact that most analyses do not result in
extraction of 100 percent of the constituent. In assessing the
recovery data to be transferred, the procedures outlined in (1).
(2), and (3) above are followed.
The analytical procedures employed to generate the data used to
calculate the treatment standards are listed in Appendix B of this
document. In cases where alternatives or equivalent procedures and/or
equipment are allowed in EPA's SW-846, Third Edition methods, the
1-35
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specific procedures and equipment used are documented. In addition, any
deviations from the SW-846, Third Edition methods used to analyze the
specific waste matrices are documented. It is important to note that the
Agency will use the methods and procedures delineated in Appendix B to
enforce the treatment standards presented in Section 7 of this document.
Accordingly, facilities should use these procedures in assessing the
performance of their treatment systems.
1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes
(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 Gutd«nn«* Division. Office of Wot«r 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
-------
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
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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
-------
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
-------
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 1500°C). When the anhydrous cement
powder is mixed with water, hydration occurs and the cement begins to
set. The chemistry involved is complex because many different reactions
occur depending on the composition of the cement mixture.
As the cement begins to set, a colloidal gel of indefinite
composition and structure is formed. Over 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
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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
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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
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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
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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
-------
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.
-------
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
-------
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
-------
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
-------
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.
£$?VJrtus' information is necessary to determine what, if any,
V£ Jirpcessing is required for final disposal of such soil
e facility this procedure has been developed for is
Army Ammunition Plant, Milan, Tennessee. There are
eleven lagoons located at this facility that have been used
tp process waters containing nitrobodies; specifically,
what is classified as pink water. The closing out of these
lagoons has a high priority within the Army and EPA
because groundwater has been contaminated within the arsenal
boundaries. There is an immediate need to develop a strategy
tp plose out these lagoons, either by filling or treating the
sediments.
~M
Feel free to contact Mr. Robert A. Breschi, who is referred
j*in the enclosed documents. Once your review has been
»pleted, we need to develop a mutual time during which
^3 Can discuss this procedure with Mr. Breschi and other
representatives of the u. S. Army Toxic and Hazardous
" " ' • Agency.
sting that you respond to my request by
11, 1981. I am targeting a meeting with the
.. Toxic and Hazardous Materials Agency during
of September 21.
r,**--*
E-3
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DEPARTMENT OF THE ARMY
US AIWY TOXIC AMD HAZARDOUS «*U»IAUS
1KHO
Hr. Art Llnton .^_ _.-.
Federal Activities Coordinator (Rm 203)
Efjylroiwental Protection Agency
34$ Courtland Street
Atlanta, Georgia 30365
Dear Hr. Llnton:
-•geS^'5'HffSSSMSsr'
'situated at Milan AAP. J.
"1«m.m 1 .«< 2 .» copies of t^e r!ju«s « deterge ^cjnt^
°^v?rP^™sl?^rtU?r.SUheiflCSi"UrnA.di«nt .„ ,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
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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.
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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.
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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.
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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 75°C and
maintain at 75°C for 48 consecutive hours. Temperatures will be continuously
recorded. Constant observation is not required. Record results on data sheet.
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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 25°C 5°C. 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.
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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 75°C (167°F).
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 75°C (167°F).
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.
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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 10°F. 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.
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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.
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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.
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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 75°C in vented oven.
Card Gap Test Samples: 3 Tubes
Detonation: Yes
No
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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
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