FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT FOR
K060
Larry Roaangrant, Chief
Treatment Technology Section
Monica Chataon-McEaddy
Project Manager
U.S. Exnrironaental Protection Agency
Office of Solid ¥aate
401 M Street, S.V.
Washington, DC 20460
May 1990
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TABLE OF CONTENTS
Page No.
Section
1. INTRODUCTION AND SUMMARY 1-1
2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industry Affected and Process Description 2-1
2.2 Waste Characterization 2-3
3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.2 Demonstrated Treatment Technologies 3-4
4. PERFORMANCE DATA 4-1
5. DETERMINATION OF BEST DEMONSTRATED AVAILABLE
TECHNOLOGY (BOAT) 5-1
5 .1 BOAT for Organics 5-2
5.2 BOAT for Cyanides 5-3
6. SELECTION OF REGULATED CONSTITUENTS 6-1
6.1 Identification of BOAT List Constituents 6-1
6.2 Constituent Selection 6-2
7. DEVELOPMENT OF BOAT TREATMENT STANDARDS 7-1
8. REFERENCES 8-1
ii
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LIST OF TABLES
Page No,
Table 1-1 Treatment Standards for K060 Waste 1-5
Table 2-1 Total Content Analysis of Ammonia Still Prelimer
Line Sludge 2-4
Table 2-2 Characterization Data for Samples Taken Before
and After Treatment of Coke-Making Facility
Wastewaters 2-5
Table 4-1 Analytical Results for K087 Untreated Waste
Collected Prior to Treatment by Rotary Kiln
Incineration 4-4
Table 4-2 Analytical Results for Kiln Ash Generated by
Rotary Kiln Incineration of K087 Waste 4-6
Table 4-3 Analytical Results for Scrubber Water Generated
by Rotary Kiln Incineration of K087 Waste 4-8
Table 4-4 Characterization Data for Samples Taken Before
and After Treatment of Coke-Making Facility
Wastewaters 4-10
Table 6-1 Potential Candidates for Regulation 6-3
Table 7-1 Calculation of Nonwastewater Treatment Standards
for Regulated Constituents in K060 Waste 7-4
Table 7-2 Calculation of Wastewater Treatment Standards for
Regulated Constituents in K060 Waste 7-5
Table 7-3 Treatment Standards for K060 Waste 7-6
LIST OF FIGURES
Page No.
Figure 2-1 Ammonia Still Lime Sludge Generation 2-2
iii
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ACKNOWLEDGMENTS
This document was prepared for the U.S. Environmental Protection
Agency, Office of Solid Waste, by Versar Inc., under Contract No.
68-W9-0068. Mr. Larry Rosengrant, Chief, Treatment Technology Section,
Waste Treatment Branch, served as the EPA Program Manager for the BOAT
program. Mrs. Monica Chatmon-McEaddy served as the Project Manager for
K060 waste regulatory development. Mr. Steven Silverman served as EPA
legal advisor.
The following personnel from Versar Inc. were involved in preparing
this document. Mr. Jerome Strauss, Program Manager; Mr. Stephen Schwartz,
Assistant Program Manager; Ms. Roberta Eelman, Staff Engineer; Ms. Sally
Gravely, Program Secretary; and Ms. Martha Martin, Technical Editor.
iv
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1. INTRODUCTION AND SUMMARY
Pursuant to section 3004(m) of the Resource Conservation and
Recovery Act (RCRA) as enacted by the Hazardous and Solid Waste
Amendments on November 8, 1984, the Environmental Protection Agency (EPA)
is promulgating best demonstrated available technology (BOAT) treatment
standards for K060 waste (ammonia still lime sludge resulting from
addition of lime during ammonia stripping). Compliance with the BOAT
treatment standards is a prerequisite for the placement of the waste in
facilities designated as land disposal units according to 40 CFR
Part 268. The effective date of the K060 treatment standards is
August 8, 1990.
This background document provides the Agency's technical support and
rationale for selecting and developing the proposed treatment standards
for the constituents to be regulated in K060 waste. This document
explains how EPA determines BOAT, selects constituents for regulation,
and calculates treatment standards. Section 2 presents waste-specific
information--the number and location of facilities affected by the land
disposal restrictions, the waste-generating process, and waste
characterization data. These data serve as a basis for determining
whether a variance from treatment standards may be warranted for a
particular type of K060 that is more difficult to treat than the wastes
that were analyzed in developing the K060 treatment standards. Section 3
discusses the technologies used to treat the waste (or similar wastes),
and Section 4 presents available performance data, including data on
which the treatment standards are based. Section 5 explains EPA's
determination of BOAT, while Section 6 discusses the selection of
constituents to be regulated. The treatment standards are determined in
Section 7.
The BOAT program, the Agency's legal authority, and promulgated
methodology are described in detail in two additional documents:
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Methodology for Developing BOAT Treatment Standards (US.EPA 1989e) and
Generic Quality Assurance Project Plan for Land Disposal Restrictions
Program ("BOAT") (USEPA 1987). The petition process to be followed in
requesting a variance fr.im the BOAT treatment standards is also discussed
in the methodology document.
Under 40 CFR 261.32, wastes identified as K060 are listed as
follows: ammonia still lime sludges. The Agency believes that only one
facility generates this waste; this facility claims that it recycles K060.
In the August 17, 1988, final rule, the Agency promulgated "No Land
Disposal Based on No Generation" for K060 nonwastewaters. EPA amended
this standard in the May 2, 1989, rule to apply only to certain newly
generated wastes. The Agency is revoking this standard since a facility
can use ammonia instead of the currently used sodium hydroxide as a
reagent in the coking process and thereby generate K060.
Five constituents are being regulated in both nonwastewater and
wastewater forms of K060 waste--benzene, benzo(a)pyrene, naphthalene,
phenol, and total cyanides. For the purpose of determining the
applicability of the treatment standards, wastewaters are defined as
wastes containing less than 1 percent (weight basis) total suspended
solids* and less than 1 percent (weight basis) total organic carbon
(TOC). Waste not meeting this definition must comply with the treatment
standards for nonwastewaters.
* The term "total suspended solids" (TSS) clarifies EPA's previously used
terminology of "total solids" and "filterable solids." Specifically,
the quantity of total suspended solids is measured by Method 209c,
Total Suspended Solids Dried at 103 to 105°C, in Standard Methods
for the Examination of Water and Wastewater, 16th Edition (APHA, AWWA,
and WPCF 1985).
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The Agency does not have performance data for treatment of K060;
therefore, the promulgated treatment standards for the regulated volatile
and semivolatile organic constituents and cyanides in the nonwastewater
form are transferred from treatment performance from incineration of K087
wastes. The Agency believes that the transfer is technically feasible
because these two wastes are generated from the same industry and contain
the same constituents.
The promulgated treatment standard for these regulated volatile and
semivolatile organic constituents and cyanides in the wastewater residual
are transferred from treatment performance of biological treatment
followed by settling and clarification. The wastewater treatment
performance data are available from the EPA Office of Water Development
Document for Effluent Guidelines and Standards for the Iron and Steel
Industry Manufacturing Point Source Category Coke Making Manufacture
(USEPA 1982). The Agency is regulating only total cyanides as opposed to
both total and amenable cyanides because the characterization data
appearing in Section 2 show amenable cyanides present in the untreated
waste at <1.0 ppm, while total cyanides are present at higher levels in
the untreated waste.
Table 1-1 lists the specific nonwastewater and wastewater treatment
standards for K060 waste. The treatment standards for organics and total
cyanides reflect the total constituent concentration; the units are mg/kg
(parts per million on a weight-by-weight basis) for the nonwastewaters
and mg/1 (parts per million on a weight-by-volume basis) for the
wastewaters. Wastewater numbers are based on a 24-hour composite grab
sample.
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Table 1-1 Treatment Standards for K060 Haste
Constituent
Honwastewaters
Total
concentration
(n«/ks)
(grab samples)
Hastewaters
Total concentration
(24-hour composite
sample except for
cyanides )
Volatile ornanics
Benzene
0.071
0.17
Semivolatile organics
Benzo ( a )pyr ene
Haphtbalene
Rienol
Inorganics
Cyanides (total)
3.6
3.4
3.4
1.2
0.03S
0.028
0.042
6.6
HA = Hot applicable.
3222g
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2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
According to 40 CFR 261.32, the waste K060 is listed as follows:
K060: Ammonia still lime sludge from addition of lime during
ammonia stripping.
This section describes the K060 waste, its generation, and the industry
affected by the land disposal restriction of the waste.
2.1 Industry Affected and Process Description
K060 waste is a coke-making byproduct waste from the iron and steel
industry (Standard Industrial Classification (SIC) code 3312). The
Agency knows of only one facility that currently generates K060 waste as
listed. This facility claims that its K060 is being recycled.
The following description of the process was presented in the RCRA
Listing Background Document for K060 (USEPA 1980).
Ammonia still lime sludge is generated from coke-manufacturing
operations during the recovery of ammonia by the addition of lime to the
ammonia still contents. Figure 2-1 illustrates the process from which
the waste K060 is generated. In this process, excess ammonia liquor is
passed through stills to strip the ammonia (NH.,) from solution for
subsequent recovery as ammonium sulfate, phosphate, or hydroxide. About
half of the ammonia originally present strips readily, but the remaining
fraction can be recovered only by elevating the pH of the waste liquor to
10-12 through the addition of lime and then passing additional steam
through the solution. This stripping transfers the rest of the ammonia
to the gas stream. Other ammonia liquor components remain behind. As a
result, the lime sludges contain treatable levels of hazardous
constituents.
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COOLING
JACKET
AMMONIA
LIQUOR
ro
STEAM
STEAM
TO AMMONIA ABSORBER-
COOLING WATER
COOLING WATER RETURN
DEPHLEGMATOR
SECTION
LIME SLURRY
STEAM
AMMONIA STILL
WASTE LIQUOR SETTLING BASIN
WEAK AMMONIA LIQUOR TO
FURTHER TREATMENT
LIME STILL SLUDGES
PERIODICALLY REMOVED
FOR DISPOSAL (K060)
FIGURE 2-1 AMMONIA STILL LIME SLUDGE GENERATION
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2.2 Waste Characterization
Some characterization data are available from the EPA Office of Solid
Waste relisting effort, including data on BDAT list constituent
concentrations in ammonia still "prelimer" lime sludge obtained at two
byproduct coke plants.* These data are not from K060. The prelimer
consists of a continuous treatment tank in which lime is added to the raw
ammonia-rich liquor prior to stripping. By not adding the lime directly
into the still, the generator of the "prelimer" waste avoids a K060
listing for this waste material. The analyses of the sludge formed in
the prelimer provide an indication of the BDAT list constituents expected
to be present in K060 wastewater (see Table 2-1). These constituents
include benzene, phenols, naphthalene, and cyanides. The pollutant
levels shown represent concentrations in the solid portion of the sludge
and provide no indication of what levels would exist in the wastewater
leaving the ammonia stripper.
* Data to be presented in a forthcoming EPA/OSW background document:
Analytical Data Report for Bethlehem Steel Corp., Bethlehem,
Pennsylvania. EPA Contract 68-01-7287, Work Assignment 14, MRI
Project 9101-13.
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Table 2-1 Total Content Analysis of Ammonia
Still Prelimer Lime Sludge
Coke Plant 3 Coke Plant 7
Constituent (mg/kg) (mg/kg)
Phenol
2 -Methyl phenol
4 -Methyl phenol
2 , 4 - Dime thylphenol
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benz ( a ) anthr ac ene
Chrysene
Benzo(b)fluoranthene
Benzo (k) f luoranthenea
Benzo(a)pyrene
Dibenz (a , h) anthracene
Indeno(l , 2 , 3-c ,d)pyrene
Benzo(g,h. i)perylene
Arsenic
Barium
Cadmium
Chromium
Lead
140
20.9
59.6
5.44
6.14
3.48
0.166
1.78
5.13
2.27
4.32
2.44
1.26
1.24
4.86
--
1.98
<0.12
<0.12
2.80
2.7 (0.055 mg/l)b
3.1 (1.52 mg/l)b
<0,4 (<0.004 mg/l)b
3.8 (0.008 mg/l)b
<5.1 (0.051 mg/l)b
533
106
286
27.2
199
224
15.1
194
370
160
269
202
155
115
289
--
93.1
17.0
38.4
34.1
83.5 (0.059 mg/r)b
10.7 (1.37 mg/l)b
<0.4 (0.007 mg/l)b
7.40 (0.015 mg/l)b
6.85 (<0.051 mg/l)b
Cyanide, total 0.44 (15.9 mg/l)b 769 (11.6 mg/l)b
Cyanide, amenable <1.0 (10.5 mg/l)b <1.0 (10.8 mg/l)b
a Included with benzo(b)fluoranthene.
b Concentrations in parentheses are TCLP extract concentrations.
Source: Unpublished data obtained under the EPA/OSW hazardous waste listing
program effort for the byproduct coke-making industry.
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3595g
Table 2-2 Characterization Data for Samples Taken Before and After
Treatment of Coke-Making Facility Wastewaters
Constituents
Concentration (mq/1)
Plant 003a
Before After
Benzene
2,4,6-Trichlorophenol
Chloroform
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Naphthalene
4,6-Dinitro-o-cresol
Pentachlorophenol
Phenol
Phthalates, Total
Benzo( a )anthracene
Benzol a (pyrene
Chrysene
Acenapthylene
Fluorene
Pyrene
Toluene
Xylene
Ant imony
Arsenic
Cyanides
Selenium
Silver
Zinc
27.2
ND
1.37
5.33
NO
ND
0.640
3.13
28.9
ND
ND
327
2.30
ND
ND
ND
6.37
2.47
2.63
8.92
<0.01
NA
NA
22.3
NA
<0.00
0.130
<0.060
ND
<0.281
ND
ND
ND
0.039
0.008
ND
ND
ND
<0.015
0.192
<0.002
0.013
<0.006
<0.007
<0.010
0.026
0.040
ND
NA
NA
2.34
NA
<0.002
0.060
pH (Units)
9.6-9.8
7.4-7.5
ND = None detected.
NA = Not analyzed.
aThe "before" column characterizes the feed concentration to the ammonia
still; the "after" column shows wastewater concentrations following bio-
logical treatment, settling, and clarification.
Source: USEPA 1982, Table VII-3, p. 88.
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3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
This section identifies the treatment technologies that are
applicable to K060 waste and determines which, if any, of the applicable
technologies can be considered demonstrated for the purposes of
establishing BOAT.
To be applicable, a technology must be theoretically usable to treat
the waste in question, or to treat a waste that is similar in terms of
the parameters that affect treatment selection. (For detailed
descriptions of the technologies applicable for these wastes, or for
wastes judged to be similar, see EPA's Treatment Technology Background
Document (USEPA 1989b).) To be demonstrated, the technology must be
employed in full-scale operation for the treatment of the waste in
question or a similar waste. Technologies available only at research
facilities or in pilot- and bench-scale operations are not considered in
identifying demonstrated technologies.
3.1 Applicable Treatment Technologies
As explained in Section 2.2, K060 waste may contain organic
constituents and cyanides. Applicable technologies for treating organic
constituents in a waste or in any resulting treatment residuals include
technologies that destroy or reduce the amount of the constituents
present in the waste. Applicable technologies for cyanides include those
that destroy or reduce the amount of cyanides present in a waste. The
applicable technologies that are described below were identified based on
current literature sources, field testing, and current waste treatment
practices.
The Agency has identified fuel substitution and incineration as
applicable technologies for treating the organic constituents and
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cyanides in untreated as-generated K060 waste. Also, because the one
facility that is believed to generate K060 recycles this waste, recycling
is considered an applicable technology. As treatment processes, fuel
substitution and incineration have the same purpose: to thermally
destroy the organic constituents and cyanide in the waste by converting
them to carbon dioxide and water. Fuel substitution, in addition, uses
the waste as a substitute for conventional fuels burned in
high-temperature industrial processes.
Both fuel substitution and incineration generally result in
nonwastewater and wastewater treatment residuals such as ash, clarifier
solids from the flue gas scrubber system, and scrubber water, which may
require further treatment. The residuals from treatment of K060 waste in
a well-designed, well-operated fuel substitution combustion device or
incinerator are not expected to contain detectable levels of organic
constituents or cyanide and thus should not require further treatment for
organics.
The wastewater residual generated by incineration of K060 waste is
not expected to contain treatable levels of organics. If, however, a
K060 wastewater is generated via landfill leachate or through mixture
with other wastes, the organics in the wastewater probably will require
treatment. The Agency has identified wet air oxidation, biological
treatment, and carbon adsorption as applicable .technologies in treating
the wastewater form of K060.
Wet air oxidation is a treatment technology applicable to wastewaters
containing organics and cyanides and is typically used to oxidize sludge,
regenerate spent activated carbon, and treat process wastewaters. This
technology can be used to treat wastewaters that have higher organic
concentrations than are normally handled by biological treatment, carbon
adsorption, and chemical oxidation, but may be too dilute to be
effectively treated by thermal processes such as incineration. Wet air
3-2
322*8
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oxidation is most applicable for waste streams containing dissolved or
suspended organics in the 500 to 15,000 mg/1 range. Below 500 mg/1, the
rates of wet air oxidation of most organic constituents are too slow for
efficient application of this technology. For these more dilute waste
streams, biological treatment, carbon adsorption, or chemical oxidation
may be more applicable. For more concentrated waste streams (above
15,000 mg/1), thermal processes such as incineration may be more
applicable. Wet air oxidation can also be applied to wastes that have
significant concentrations of metals (roughly 2 percent), whereas
biological treatment, carbon adsorption, and chemical oxidation may have
difficulty in treating such wastes.
Biological treatment is a technology that uses living microorganisms
to decompose organic constituents and can also be used to treat cyanides
at relatively low concentrations. Biological treatment can occur either
in the presence of oxygen, where it is known as aerobic treatment, or in
the absence of oxygen, where it is referred to as anaerobic treatment.
The organic constituents are broken down into water, carbon dioxide, and
other organic constituents by the microorganisms.
Carbon adsorption is a separation technology used to remove and/or
recover dissolved organics and certain inorganics from aqueous streams by
adsorbing the dissolved constituents onto the surface of the activated
carbon particles. Powdered or granular activated carbon particles are
used as the adsorbing medium in this technology.
The above technologies applicable to treating wastewaters containing
organics are discussed in detail in the Treatment Technology Background
Document (USEPA 1989b).
Because K060 waste contains cyanides, wastewater residuals may
contain treatable levels of these compounds. The scrubber water
3-3
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generated by incineration of K060 waste is not expected to contain
treatable levels of cyanides. If, however, a K060 wastewater is
generated via landfill leachate or mixture with other wastes, the
cyanides will require further treatment. The applicable technology for
treatment of cyanides in K060 is biological treatment which has been
previously described. The nonwastewater residuals of K060 should not
contain treatable levels of cyanides; these constituents in the
nonwastewater form should be adequately destroyed during incineration.
3.2 Demonstrated Treatment Technologies
The only known generator of K060 waste is believed to recycle this
waste; therefore, the Agency has no data indicating that incineration or
fuel substitution is being used on K060 waste. The Agency does have
data, however, on incineration of K087, a waste believed to be similar to
K060. These wastes are believed similar because both K087 and K060 are
generated through the manufacture of coke in the iron and steel industry
and because both wastes contain similar constituents (i.e., benzene,
phenols, naphthalene, and cyanides) that are present in treatable
concentrations. EPA believes, therefore, that incineration would be a
demonstrated technology for K060 waste in destroying nonwastewater
organic and cyanide constituents.
Incineration, as stated previously, is a demonstrated treatment
technology for organic and cyanide nonwastewater removal in K060 waste.
Also, as previously discussed, recycling is a demonstrated technology for
K060 because the only facility currently generating K060 recycles this
waste.
The Agency has no data indicating that wet air oxidation, carbon
adsorption, or biological treatment are being used on K060 wastewaters.
Data are available, however, for biological treatment of a waste similar
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to K060 in that it is generated by the iron and steel industry in coke
manufacturing and the constituents treated by biological treatment
(naphthalene, phenols, benzene, and cyanides) are also present in
treatable levels in K060. The Agency believes that biological treatment
is a demonstrated technology for treatment of organics and cyanides in
K060 wastewaters.
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4. PERFORMANCE DATA
This section presents the data available to EPA on the performance of
demonstrated technologies in treating the listed wastes. These data are
used elsewhere in this document for determining which technologies
represent BDAT (Section 5), for selecting constituents to be regulated
(Section 6), and for developing treatment standards (Section 7).
Eligible data, in addition to full-scale demonstration data, may include
data developed at research facilities or obtained through other
applications at less than full-scale operation, as long as the technology
is demonstrated in full-scale operation for a similar waste or wastes as
defined in Section 3.
Performance data, to the extent that they are available to EPA,
include the untreated and treated waste concentrations for a given
constituent, values of operating parameters that were measured at the
time the waste was being treated, values of relevant design parameters
for the treatment technology, and data on waste characteristics that
affect performance of the treatment technology.
Since data are not available on the treatment of K060 wastes, the
Agency has elected to transfer treatment performance for a similar waste,
using a demonstrated technology. To transfer treatment performance data
from another waste category, EPA must find that the wastes covered by
this background document are no more difficult to treat (based on the
waste characteristics that affect performance of the demonstrated
treatment technology) than the treated waste from which performance data
are being transferred.
No performance data are available to the Agency to characterize
treatment of organics and cyanides in K060 nonwastewaters. However, the
Agency has data for incineration of a similar organic waste, K087, which,
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as defined by 40 CFR 261.32, is the decanter tank car sludge from coking
operations. This similarity is based on the production processes, the
waste compositions, and the waste characteristics affecting performance
of the demonstrated treatment technology. The waste characteristics
affecting performance of incineration are bond dissociation energies and
boiling points. These are described in the Treatment Technology
Background Document (USEPA 1989b). Evaluation of the waste composition
for K060 reveals that the primary constituents of concern in K060 are
present in higher concentrations in K087. For instance, K060 contains
phenol at 533 ppm at its highest value while K087 contains phenol at
1,800 ppm. Therefore, the Agency is transferring performance data for
organics and cyanides in the nonwastewater form of K060 from the
treatment of K087 wastes since the Agency believes that K060 is no more
difficult to treat than the tested K087 waste.
No performance data are available to characterize treatment of
organics and cyanides in K060 wastewaters. Data are available for
biological treatment of organics and cyanides in wastewaters from the
Office of Water Development Document for Effluent Guidelines and
Standards for the Iron and Steel Manufacturing Point Source Category Coke
Making Manufacture (USEPA 1982). The Agency believes that wastewaters
generated from the Effluent Guidelines process have similar
characteristics to K060 wastewaters because the wastewaters are generated
from a similar industry (coke making) and a process that is nearly
identical to the K060 process (the Effluent Guidelines process uses a
prelimer; K060 does not).
The performance data used for transfer include the untreated and
treated waste concentrations for a given constituent, the values of
operating parameters that were measured at the time the waste was being
treated, the values of relevant design parameters for the treatment
technology, and data on waste characteristics that affect the performance
of the treatment technology.
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Because the Agency is transferring performance data from K087 to K060
for organic and cyanide nonwastewaters, tables 4-1 through 4-3 present
the data of total waste concentration analyses for treated and untreated
K087 waste. In all cases, the BDAT list organics and cyanides detected
in the K087 untreated waste are reduced to nondetectable levels in the
treated residuals. Table 4-4 presents the data of total waste
concentration analyses for treated and untreated organics and cyanides in
a coke manufacturing wastewater.
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3266g
Table 4-1 Analytical Results for K087 Untreated Waste Collected
Prior to Treatment by Rotary Kiln Incineration
Constituent/parameter (units)
BOAT Volatile Organ ics (mg/kg)
Benzene
Methyl ethyl ketone
Toluene
Xylenes
BOAT Sanivolatile Organ ics (mg/kg)
Acenaphthalene
Anthracene
Benz ( a ) ant hracene
Benzo(b)f luoranthene
Benzo ( k ) f 1 uoranthene
Benzo(a)pyrene
Chrysene
para-Cresol
F luoranthene
Fluorene
Indeno(l,2.3-c,d)pyrene
Naphthalene
Phenanthrene
Phenol
Pyrene
BOAT Metals (mg/kg)a
Ant inony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
1
17
<2.0
17
21
11000
7500
5700
3200
3100
4100
5100
1600
11000
7600
2100
64000
34000
1600
9100
<2.0
6.1
<20
<0.5
1.7
<2.0
3.2
85
2.9
<4.0
1.2
<5.0
2.7
<5.0
63
2
19
<2.1
17
23
12000
8100
5900
<1010
7500
4300
5300
1600
12000
7900
2500
66000
34000
1SOO
5900
<2.0
6.1
<20
<0.5
2.1
<2.0
4.5
80
3.6
4.6
1.6
<5.0
2.3
<5.0
63
Concentration
Samole set t
3
5.6
<2.0
5.0
3.0
10000
7100
5600
3100
3100
4100
5100
1300
11000
7000
2300
64000
15000
1200
8000
<2.0
5.5
<20
<0.5
2.1
<2.0
3.2
72
3.8
«4.0
1.3
<5.0
2.2
<5.0
58
4
212
<10
152
123
13000
8100
7500
<982
9300
5400
6500
1900
<982
9300
3100
81000
41000
1800
9700
<2.0
1.9
<20
<0.5
1.7
<2.0
<2.5
64
4.2
<4.0
1.4
<5.0
2.1
<5.0
50
5
170
<10
130
121
10000
6700
5400
5300
<1026
3800
4700
1200
11000
7000
2100
63000
15000
1200
8100
<2.0
5.2
<20
<0.5
1.9
<2.0
2.6
69
3.3
<4.0
1.2
<5.0
2.2
<5.0
66
4-4
-------
3266g
Table 4-1 (continued)
Constituent/parameter (units)
BOAT Inorganics Other Than Metals (og/kg)
Cyanide
Fluoride
Sulfide
Non-BDAT Volatile Organ Ics (mg/kg)
Styrene
Non-BDAT Semi volatile Organ ics (mg/kg)
Olbenzofuran
2-Metnylnaphthalene
Other Parameters
Ash content (X)
1
22.8
0.38
323
12
5300
7000
2.9
Heating value (Btu/lb) 15095
Percent water (X)
Total halogens as chlorine (X)
Total organic carbon (X)
Total organic halides (mg/kg)
Total solids (X)b
Viscosity0
Elemental constituents (X)
Carbon
Hydrogen
Nitrogen
Oxygen
5.70
0.033
83.67
27.0
87.7
-
83.80
5.62
1.13
9.13
2
18.2
-
320
12
5600
6900
3.4
14898
10.31
0.023
76.38
28.0
90.5
-
81.90
5.14
1.06
11.94
Concentration
Sample set t
3
21.1
-
275
3.4
5200
6300
9.7
14823
11.26
0.026
84.27
29.3
91.1
-
84.01
5.27
1.03
10.25
4
22.0
-
293
26
6800
9400
3.7
15336
7.72
0.045
79.10
87.7
89.7
-
66.36
6.46
0.82
26.59
5
17.9
0.18
302
71
5000
6200
2.7
14959
6.60
0.057
85.57
25.8
86.5
-
77.54
5.97
0.96
15.71
- = Not analyzed.
NO = Not detected; estimated detection li»1t has not been determined.
Results have been reported on a wet weight basis.
h'otal solids results are biased low because of test complications arising from waste matrix.
cBecause of the high concentration of solids in the waste, viscosity values could not be determined.
Note: This table shows concentrations or maximum potential concentrations in the untreated waste for all
constituents detected in the untreated waste or detected In the residuals generated by treatment of the
waste.
Source: USEPA 1988a.
4-5
-------
3266g
Table 4-2 Analytical Results for Kiln Ash Generated by
Rotary Kiln Incineration of K087 Waste
Concentration
Constituent/parameter (units)
BOAT Volatile Oraanics (na/ka)
Benzene
Methyl ethyl ketone
Toluene
Xylenes
BOAT Sani volatile Oraanics lua/ka]
Acenaphtha lene
Anthracene
Benz ( a ) ant hracene
Benzo(b)fluoranthene
Benzo(k)f1uoranthene
Benzo(a)pyrene
Chrysene
para-Cresol
Fluoranthene
Fluorene
Indeno( 1 , 2 . 3-c , d)pyrene
Naphthalene
Phenanthrene
Phenol
Pyrene
BOAT Metals (nn/ka)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
1
<25
<25
150
<25
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<3.2
9.9
317
0.60
<0.40
34
746
44
<0.10
10
1.4
<0.60
<1.0
17
SO
San
2
<25
<25
85
<25
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<2.0
11
56
<0.5
<1.0
5.2
44
8.2
2.8
<4.0
1.6
<5.0
<1.0
9.7
13
Die set f
3
<25
<25
<25
<25
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<2.0
6.7
53
<0.5
<1.0
2.2
43
8.3
2.9
<4.0
<0.50
<5.0
<1.0
6.6
13
4
<25
<25
<25
<25
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<2.0
12
41
«0.5
<1.0
2.1
50
5.9
3.3
<4.0
5.9
<5.0
<1.0
B.I
12
5
<25
<25
190
<25
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<1000
<3.2
5.3
63
0.36
<0.40
7.6
94
7.2
<0.1
4.5
<0.5
<6.0
<1.0
10
21
4-6
-------
3266g
Table 4-2 (continued)
Constituent/parameter (units)
BOAT TCLP: Metals (iia/1)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
BOAT Inorganics Other Than Metals (rag/kg)
Cyanide
Fluoride
Sulfide
Non-BOAT Volatile Organ ics (/ig/kg)
Styrene
Non-BDAT Semi volatile Orqanics (pg/kg)
Dibenzofuran
2-Methylnaphthalene
Other Parameters (ng/kg)
Total organic carbon
Total chlorides
Total organic ha 1 ides
1
425
96
609
3.3
<4.0
62
<6.0
29
<0.2
93
<50
<6.0
<10
<30
169
0.74
<1.0
35.5
<25
<1000
<1000
350000
9.7
375
2
<20
33
344
<5.0
<10
<20
52
40
<0.30
<40
7.3
<50
<10
<50
202
<0.50
-
36.3
<25
<1000
<1000
553000
6.8
18.3
Concentration
Sample set t
3
<20
25
547
<5.0
<10
<20
1110
53
<0.30
<40
<5.0
<50
<10
<50
218
<0.50
-
144
<25
<1000
<1000
402000
14.1
32.1
4
<20
19
641
<5.0
<10
<20
346
20
<0.30
<40
<5.0
<50
<10
<50
288
<0.50
-
116
<25
<1000
<1000
316000
14.6
19.8
5
<32
43
546
2.5
<4.0
8.7
497
106
<0.2
16
<5.0
<6.0
<500
8.3
256
<0.50
<0.25
11.0
<25
<1000
<1000
244000
16.0
133
- = Not analyzed.
Note: This table shows the concentrations or •ax1n0 potential concentrations in the kiln ash for all
constituents that were detected in the untreated waste or detected in residuals generated from treatment of
the waste.
Source: USEPA 1988a.
4-7
-------
3266g
Table 4-3 Analytical Results for Scrubber Water Generated by Rotary Kiln
Incineration of KOB7 Waste
Constituent/parameter (units)
BOAT Volatile Organ ics (
-------
3266g
Table 4-3 (Continued)
Concentration
a
Constituent/parameter (units) Samole
12344
BOAT Inoraanics Other Than Metals (ma/1)
Cyanide <0.01 <0.01 <0.01 <0.01 <0.01
Fluoride 3.38 2.99 2.38
Sulfide <1.0 <1.0 11.9 <1.0 <1.0
Non-BDAT Volatile Oroanics Ug/1)
Styrene <5 <5 <5 <5 <5
Non-BDAT Semivolatile Organ Ics (/ig/1)
Dibenzofuran <10 <10 <10 <10 <10
2-Methylnaphthalene <10 <10 <10 <10 <10
Other Parameters
Total organic carbon (rag/1) 37.9 26.1 88.9 148 111
Total solids (mg/1) 2240 2080 1910 2350 2480
Total chlorides (mg/1) 51.3 57.9 48.5 51.0 58.3
Total organic ha 1 ides (jig/1) 33.7 33.2 48.7 23.3 27.6
6
<0.01
3.54
<5
HI
94.1
2720
56.0
27.4
- = Not analyzed.
aScrubber water samples are not assigned a sample set number.
Note: This table shows concentrations or maximum potential concentrations in the scrubber
Mater for all constituents detected in the untreated waste or detected in residuals generated
from treatment of the waste.
Source: USEPA 1988a.
4-9
-------
3266g
Table 4-4
Characterization Data for Samples Taken Before and After
Treatment of Coke-Making Facility Uastewaters
Constituents
pH (Units)
Concentration (rng/1)
Plant 003a
Before
9.6-9.8
After
Benzene
2,4.6-Trichlorophenol
Chloroform
2,4-Dimethylphenol
2.4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Naphthalene
4 , 6-D i n i tro-o-creso 1
Pentach loropheno 1
Phenol
Phthalates, Total
Benzo(a)anthracene
Benzo(a)pyrene
Chrysene
Acenapthylene
Fluorene
Pyrene
Toluene
Xylene
Antimony
Arsenic
Cyanides
Seleniin
Silver
Zinc
27.2
NO
1.37
5.33
ND
NO
0.640
3.13
28.9
ND
NO
327
2.30
NO
NO
ND
6.37
2.47
2.63
8.92
<0.01
NA
NA
22.3
NA
<0.00
0.130
<0.060
NO
<0.281
ND
ND
ND
0.039
0.008
ND
NO
ND
<0.015
0.192
<0.002
0.013
<0.006
<0.007
<0.010
0.026
0.040
ND
NA
NA
2.34
NA
<0.002
0.060
7.4-7.5
NO « None detected.
NA * Not analyzed.
aThe "before" colum characterizes the feed concentration to the anaemia
still; the "after" colum shows wastewater concentrations following bio-
logical treataent, settling, and clarification.
Source: USEPA 1982, Table VI1-3, p. 88.
4-10
-------
5. IDENTIFICATION OF BEST DEMONSTRATED
AVAILABLE TECHNOLOGY (BDAT)
This section presents the Agency's rationale for determining best
demonstrated available technology (BDAT) for K060 nonwastewaters and
wastewaters.
To determine BDAT, the Agency examines all available performance data
on technologies that are identified as demonstrated on the waste of
concern or similar wastes to determine (using statistical techniques)
whether one or more of the technologies performs significantly better
than the others. All performance data used for determination of best
technology must first be adjusted for accuracy, as discussed in EPA's
publication, Methodology for Developing BDAT Treatment Standards
(USEPA 1989c). (An accuracy adjustment accounts for the ability of an
analytical technique to recover a particular constituent from the waste
in a particular test. The recovery of a constituent is usually
determined by spiking a sample with a known amount of the target
constituent and then comparing the spiked sample amounts with results
from unspiked samples.) Accuracy adjustment is further discussed in
Section 7. BDAT must be specifically defined for all streams associated
with the management of the listed waste or wastes; this pertains to the
original waste as well as any residual waste streams created by the
treatment process. Additionally, the ANOVA test is available to compare
data from two or more demonstrated technologies and determine which
offers the best treatment. The ANOVA test is described fully in the
methodology background document.
The technology that performs best based on ANOVA tests on a
particular waste or waste treatability group is then evaluated to
determine whether it is "available." To be available, the technology
must (1) be commercially available to any generator and (2) provide
"substantial" treatment of the waste, as determined through evaluation of
accuracy-adjusted data. In determining whether treatment is substantial,
EPA may consider data on the performance of a waste similar to the waste
5-1
3226g
-------
in question provided that the similar waste is at least as difficult to
treat. If the best technology is found to be not available, then the
next best technology is evaluated, and so on.
5.1 BOAT for Organics
The determination of substantial treatment of organics involves
comparing constituent concentrations in the original waste to the
respective concentrations in all residual streams from treatment. There
are no available organics performance data on K060 waste as generated;
however, because of K060's similarity to K087, the Agency believes the
"best" technology chosen for K087, incineration, will apply to K060 as
well. Incineration is considered BDAT because K087 constituents (which
are also contained in K060) are reduced to nondetectable levels in the
treated residuals. Incineration of K060 waste as generated (a
nonwastewater) would produce scrubber water (wastewater) and incinerator
ash (nonwastewater), both of which should also be devoid of organic
constituents (i.e., present in amounts less than the detection limit) if
the incinerator is well-designed and well-operated. Also, since the K087
constituents were present at higher concentrations than in K060, and were
treated to nondetectable levels in K087, incineration is chosen as BDAT.
EPA has determined that incineration is commercially available.
Also, EPA believes that incineration provides substantial treatment for
organics because the performance data for K087 show that untreated
concentrations of constituents that are also present in K060 can be
reduced to nondetectable levels in both the residual nonwastewater ash
and the residual wastewater stream (the scrubber water). Thus,
incineration is "best."
As "best," "demonstrated," and "available," incineration is therefore
BDAT for organics in K060 nonwastewaters.
5-2
3226g
-------
The wastewaters generated by the incineration of K060 are not
expected to have detectable levels of organics. If, however, a K060
wastewater is generated by some other method, this wastewater will be
expected to contain treatable levels of organics. EPA has determined
that biological treatment is an available and demonstrated technology for
K060 as shown in Table 4-4. Biological treatment of K060 wastewaters has
reduced most of the organic constituents to below detection limit and is
therefore considered the "best" treatment technology for organics in K060
wastewaters. Biological treatment is, thus, BOAT for organics in K060
wastewaters.
5.2 BDAT for Cyanides
As discussed in Section 3, cyanides are not expected to be found in
the incinerator ash or scrubber waters in concentrations requiring
further treatment. Incineration is, therefore, the "best" performing
technology for cyanides in K060 nonwastewaters and wastewaters.
For cyanides in K060 wastewaters, the Agency believes that biological
treatment is "best" for treating the total cyanides. This is based on
the reduction of the total cyanide concentration in the waste tested by
the Office of Water as noted in Table 4-4 (since the Office of Water data
is being used for the standard). The Agency is, therefore, choosing
biological treatment as the best technology to treat cyanides in K060
wastewaters.
5-3
3226g
-------
6. SELECTION OF REGULATED CONSTITUENTS
This section presents the methodology and rationale for the selection
of regulated constituents for the treatment of K060.
Generally, constituents selected for regulation must satisfy the
following criteria:
1. They must be on the BOAT list of regulated constituents.
(Presence on the BOAT list implies the existence of approved
techniques for analyzing the constituent in treated waste
matrices.)
2. They must be present in, or be suspected of being present in, the
untreated waste. For example, in some cases, analytical
difficulties (such as masking) may prevent a constituent from
being identified in the untreated waste, but its identification
in a treatment residual may lead the Agency to conclude that it
is present in the untreated waste.
3. Where performance data are transferred from other constituents,
the selected constituents must be easier to treat (based on
characterization data) than the waste constituent(s) from which
performance data are transferred. Factors for assessing ease of
treatment vary according to the technology of concern. For
instance, for incineration the factors may include bond
dissociation energy, thermal conductivity, and boiling point.
From the group of constituents that are eligible to be regulated
(i.e., all constituents on the BOAT list), EPA may select a subset of
constituents as representative of the broader group. For example, out of
a group of constituents that react similarly to treatment, the Agency
might name only those that are the most difficult to treat as regulated
constituents for the purpose of setting a standard.
6.1 Identification of BDAT List Constituents
As discussed in Sections 2 and 4, the Agency has no performance data
from treatment of organics and cyanides in nonwastewater residuals of K060
6-1
3227g
-------
waste by incineration. However, untreated waste composition data were
obtained from the RCRA Listing Background Document. Performance data for
organics and cyanides in nonwastewaters are available from incineration
of K087, which the Agency believes is similar to K060 (see Sections 3 and
4): these data, therefore, represent the Agency's source of transfer for
K060. Additionally, the Agency has data on wastewaters generated in coke
manufacturing (these wastewaters are from "prelimer" lime sludge in coke
manufacturing), which the Agency believes represent a waste similar to
K060 because K060 is generated as a result of coke manufacturing and
contains similar constituents such as phenols, naphthalene, benzene, and
cyanides. These data, along with information on the K060
waste-generating process and the RCRA Listing Document data, have been
used to determine which BOAT list constituents are, or may be, present in
the waste and thus which ones are potential candidates for regulation.
Table 6-1 indicates, for the untreated waste, 12 BOAT constituents that
the Agency believes are likely to be present based on the listing
information. These constituents were also considered as candidates for
regulation.
6.2 Constituent Selection
The Agency is proposing to regulate five of the candidate BOAT
constituents believed to be present in K060. The proposed organic
constituents for regulation are those that are believed to be present in
the highest concentrations and are expected to be the most difficult to
treat based on the RCRA Listing Document. They are benzene,
benzo(a)pyrene, naphthalene, and phenol. Cyanides are considered to be
present in treatable concentrations in K060, and they are also listed for
K060 in the RCRA Listing Document; therefore, they too are proposed for
regulation.
6-2
3227g
-------
Table 6-1 Potential Candidates for Regulation in K060 Waste
Constituent
Volatile organics
Benzene3
Chloroform
Toluene
Semovolatile organics
Acenaphthalene
Benzo(a)pyrenea
Fluoranthene
Fluorene
Naphthalene3
Phenol3
Pyrene
Inorganics
Cyanides3
3 These constituents are selected for regulation.
6-3
3227 6
-------
7. DEVELOPMENT OF BOAT TREATMENT STANDARDS
The Agency bases numerical treatment standards for regulated
constituents on the performance of well-designed and well-operated BOAT
treatment systems. These standards must account for analytical
limitations in available performance data and must be adjusted for
variabilities related to treatment, sampling, and analytical techniques
and procedures.
Concentration-based BDAT standards are determined for each
constituent by multiplying the arithmetic mean of accuracy-adjusted
constituent concentrations detected in the treated waste by a
"variability factor" specific to each constituent. Accuracy adjustment
of performance data will be discussed later in this section in relation
to defining "substantial treatment."
Where EPA has identified BDAT for a particular waste, but because of
data limitations or for some other compelling reason cannot define
numerical treatment standards for that waste, the Agency may instead
require the use of that treatment process as a technology standard.
For K060 nonwastewaters and wastewaters, the Agency is setting
treatment standards for the organic and inorganic constituents as shown
in Tables 7-1 and 7-2. The organic and cyanide nonwastewater treatment
standards are based on the performance data from incineration of K087
waste (see Tables 4-1 through 4-3). The treatment standards for organics
and total cyanides in wastewater residuals are based on performance data
from biological treatment of a waste generated during coke manufacturing
(see Table 4-4).
EPA's publication, Methodology for Developing BDAT Treatment
Standards, details both accuracy adjustment and the determination and use
7-1
3228g
-------
of variability factors. The accuracy-adjusted concentration for a
constituent in a matrix is the analytical result multiplied by the
correction factor (the reciprocal of the recovery fraction).* For
example, if Compound A is measured at 2.55 mg/1 and the recovery is
85 percent, the accuracy-adjusted concentration is 3.00 mg/1:
2.55 mg/1 x 1/0.85 - 3.00 mg/1
(analytical result) (correction factor) (accuracy-adjusted concentration)
After treatment performance data are corrected for accuracy, the
arithmetic average of the corrected data is calculated for each
constituent. In cases where the constituent is not detected above its
detection limit, the detection limit is used to calculate the average
constituent concentration in the treated waste. The next step in
calculating treatment standards is to determine the variability factor
for each regulated constituent. The variability factor of treated data
is calculated by taking the natural log of the treated data and
statistically manipulating it into a normal distribution. This is
explained in detail in the methodology document.
EPA is using a variability factor of 2.8 for all of the organic
constituent treatment standard calculations for K060 nonwastewaters
because treatment performance for each constituent transferred from K087
was below the detection limit in the K087 incinerator ash. All of the
variability factors for organic constituents in K060 wastewaters are also
* The recovery fraction is the ratio of (1) the measured amount of
constituent (or surrogate) in a spiked aliquot minus the measured
amount of constituent (or surrogate) in the original unspiked aliquot
to (2) the known amount of constituent (or surrogate) added to spike
the original aliquot. (Refer to the Generic Quality Assurance Project
Plan for Land Disposal Restrictions Program ("BDAT"), USEPA 1987).
7-2
3228g
-------
2.8 because the treatment performance for each constituent transferred
from K087 was below the detection limit.
The variability factor for cyanides in K060 wastewaters was
calculated to be 1.67 based on cyanide data from incineration of K087.
The variability factor for cyanides in K060 wastewaters was determined to
be 2.8 because the biological treatment data from which the Agency
transferred standards contained only one data point.
BOAT standards are calculated for each constituent by multiplying the
arithmetic mean of the accuracy-adjusted concentrations by the
variability factor of each constituent. Table 7-3 summarizes all
treatment standards being established for K060 waste. Note that
concentrations are expressed in terms of mg/kg and mg/1 for
nonwastewaters and wastewaters, respectively.
7-3
3228g
-------
Table 7-1 Calculation of Nonwastewater Treatment Standards for
K060 Waste
Constituent
Accuracy-
corrected
analytical
values
(mg/kg)
Variability
factor
Treatment
standard
(mg/kg)
Volatile organics
Benzene
Semivolatile organics
Source: USEPA 1988.
0.026
2.8
0.071
Benzo(a)pyrene
Naphthalene
Phenol
Inorganics
Cyanides
1.29
1.21
1.21
0.70
2.8
2.8
2.8
1.67
3.6
3.4
3.4
1.2
3228g
7-4
-------
Table 7-2 Calculation of Wastewater Treatment Standards for
Constituents in K060 Waste
Constituent
Accuracy-
corrected
analytical
values
(mg/1)
Treatment
Variability standard
factor (mg/1)
Volatile oreanics
Benzene
Semivolatile organics
Source: USEPA 1982.
0.06
2.8
0.17
Benzo(a)pyrene
Naphthalene
Phenol
Inorganics
Cyanides (total)
0.013
0.010
0.015
2.34
2.8
2.8
2.8
2.8
0.035
0.028
0.042
6.6
3228g
7-5
-------
Table 7-3 Treatment Standards for K060 Waste
Constituent
Maximum for anv single grab sample
Nonwastewaters
Total
concentration
(mg/kg)
Wastewaters
Total
concentration
(mg/1)
Volatile organics
Benzene
Semivolatile organics
NA - Not applicable.
0.071
0.17
Benzo(a)pyrene
Naphthalene
Phenol
Inorganics
Cyanides
3.6
3.4
3.4
1.2
0.035
0.028
0.042
6.6
3228g
7-6
-------
8. REFERENCES
APHA, AWWA, and WPCF. 1985. American Public Health Association,
American Water Works Association, and Water Pollution Control
Federation. Standard methods for the examination of water and
wastewater. 16th ed. Washington, B.C.: American Public Health
Association.
CyanoKEM. 1989. Public comment submitted in response to EPA proposed
Land Disposal Restrictions for Second Third Scheduled Wastes,
January 11, 1989. EPA RCRA Document No. F-89-LD10-FFFFP.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1980. U.S. Environmental Protection Agency, Office of Solid
Waste. RCRA listing background document. Washington, D.C.: U.S.
Environmental Protection Agency.
USEPA. 1982. U.S. Environmental Protection Agency, Effluent Guidelines
Division. Development document for effluent limitations guidelines and
standards for the iron and steel manufacturing point source category.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1987. U.S. Environmental Protection Agency, Office of Solid
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restrictions program ("BOAT"). EPA/530-SW-87-011. Washington, D.C.:
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