FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT)
BACKGROUND DOCUMENT FOR
MERCURY-CONTAINING WASTES
D009, K106, P065, P092, AND U151
Larry Rosengrant, Chief
Treatment Technology Section
Jose Labiosa
Project Manager
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, DC 20460
May 1990
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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 during the
preparation of this document and the development of treatment standards
for the K061 wastewaters. The Technical Project Officer for the waste
was Mr. Jose Labiosa. Mr. Steven Silverman served as Legal Advisor.
Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Program Manager; Mr. Stephen Schwartz,
Assistant Program Manager; Mr. Mark Donnelly and Mr. Greg Schweer,
Principal Investigators and Authors; Ms. Justine Alchowiak, Quality
Assurance Officer; Ms. Martha Martin, Technical Editor; and Ms. Sally
Gravely, Program Secretary.
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TABLE OF CONTENTS
Section Page No,
1. INTRODUCTION AND SUMMARY 1-1
2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industries Affected and Process Descriptions 2-2
2.1.1 Manufacture of Mercury Batteries 2-5
2.1.2 Chlorine Production by the Mercury Cell Process 2-6
2.1.3 Manufacture and Use of Organomercury Fungicides
and Bactericides 2-10
2.2 Waste Characterization 2-11
2.2.1 K106 2-11
2.2.2 P065 2-17
2.2.3 P092 2-17
2.2.4 U151 2-17
2.2.5 D009 2-17
2.3 Determination of Waste Treatability Groups 2-18
2.3.1 Mercury Nonwastewaters 2-20
2.3.2 Radioactive Wastes Containing Mercury 2-24
2.3.3 Wastewaters 2-25
3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.1.1 Applicable Technologies for Nonwastewaters .... 3-2
3.1.2 Applicable Technologies for Wastewaters 3-6
3.2 Demonstrated Treatment Technologies 3-7
3.2.1 Demonstrated Technologies for Nonwastewaters .. 3-8
3.2.2 Demonstrated Technologies for Wastewaters 3-11
4. PERFORMANCE DATA 4-1
4.1 Performance Data for Nonwastewaters 4-1
4.2 Performance Data for Wastewaters 4-3
11
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TABLE OF CONTENTS (CONTINUED)
Section Page No.
5. DETERMINATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
(BOAT) 5-1
5.1 BOAT for Nonwastewaters 5-2
5.1.1 Inorganic Mercury Nonwastewaters - High-Mercury
Subcategory 5-2
5.1.2 Inorganic Mercury Nonwastewaters - Low-Mercury
Subcategory 5-8
5.1.3 Organic Mercury Nonwastewaters 5-8
5.1.4 Nonwastewaters Containing Radioactive
Materials 5-9
5.2 BOAT for Wastewaters 5-10
6. SELECTION OF REGULATED CONSTITUENTS 6-1
6.1 Nonwastewaters 6-1
6.2 Wastewaters 6-3
7. CALCULATION OF TREATMENT STANDARDS 7-1
7.1 Wastewaters 7-2
7.1.1 K016, P065, P092, and U151 Wastewaters 7-2
7.1.2 D009 Wastewaters 7-3
7.2 Nonwastewaters 7-3
7.2.1 K106 and U151 Nonwastewaters 7-3
7.2.2 P065 and P092 Nonwastewaters 7-5
7.2.3 D009 Nonwastewaters 7-7
7.2.4 Nonwastewaters Containing Radioactive
Materials 7-5
8. REFERENCES 8-1
APPENDIX A QUALITY ASSURANCE/QUALITY CONTROL DATA A-l
APPENDIX B PROPERTIES AND MAJOR USES OF THE PRINCIPAL
COMPOUNDS OF MERCURY B-l
iii
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LIST OF TABLES
Page No.
Table 1-1 BOAT Treatment Standard for K106, P065, P092,
and U151 Wastewaters 1-10
Table 1-2 BOAT Treatment Standard for D009 Wastewaters 1-11
Table 1-3-A BDAT Treatment Standard for K106 and U151
[All nonwastewaters in the High-Mercury Subcategory].. 1-12
Table 1-3-B BDAT Treatment Standard for K106 and U151
[Nonwastewaters that are residues from RMERC and are
in the Low-Mercury Subcategory] 1-13
Table 1-3-C BDAT Treatment Standard for K106 and U151
[Nonwastewaters that are not residues from RMERC and are
in the Low Mercury Subcategory] 1-14
Table 1-4-A BDAT Treatment Standard for P065
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of
mercury content 1-15
Table 1-4-B BDAT Treatment Standard for P092
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of
mercury content 1-16
Table 1-4-C BDAT Treatment Standard for P065 and P092
[Nonwastewaters that are either incinerator residues
or residues from RMERC, and are in the High-Mercury
Subcategory] 1-17
Table 1-4-D BDAT Treatment Standard for P065 and P092
[Nonwastewaters that are incinerator residues (and are
not residues from RMERC) that are also in the Low-
Mercury Subcategory] 1-18
Table 1-4-E BDAT Treatment Standard for P065 and P092
[Nonwastewaters that are residues from RMERC and are
in the Low-Mercury Subcategory] 1-19
Table 1-5-A BDAT Treatment Standard for D009
[All nonwastewaters that contain mercury and inorganics
(and are not incinerator residues) and are also in the
High-Mercury Subcategory)] 1-20
iv
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LIST OF TABLES
Page No.
Table 1-5-B BDAT Treatment Standard for D009
[All nonwastewaters that are inorganics (including
incinerator residues and residues from RMERC) and are
in the High-Mercury Subcategory]
Table 1-5-C BDAT Treatment Standard for D009
[All nonwastewaters in the Low-Mercury Subcategory] .
Table 1-6-A BDAT Treatment Standard for D009 and U151
Elemental Mercury Contaminated with Radioactive
Materials
Table 1-6-B BDAT Treatment Standard for D009
Hydraulic Oil Contaminated with Mercury and
Radioactive Materials
Table 2-1 Major Industrial Uses of Mercury
Table 2
1-21
1-22
1-23
1-24
2-4
2 Number of Producers of Chlorine Using the Mercury Cell
Process Listed by State 2-7
Table 2-3 Number of Producers of Chlorine Using the Mercury Cell
Process Listed by EPA Region 2-9
Table 2-4 Waste Composition Data for Untreated K106 Wastes 2-12
Table 2-5 Waste Composition Data for D009 Wastes 2-18
Table 4-1 Ore Roasting Performance Data from Thermal Recovery of
Mercuric Sulfide Ores Collected by EPA at Plant A 4-4
Table 4-2 APCD Cyclone Dust Composition Data from Thermal
Recovery of Mercuric Sulfide Ores Collected by EPA at
Plant A 4-9
Table 4-3 Treatment Performance Data for Retorting of K106
Hydrazine Sludge Submitted by Plant B 4-10
Table 4-4 Treatment Performance Data for Retorting of K106
Hydrazine Sludge Submitted by Plant B-2 4-14
Table 4-5 Treatment Performance Data for Retorting of Mixed
K071/K106 Waste from Literature Source A 4-15
Table 4-6 Treatment Performance Data for Retorting of K106
Sodium Borohydride Sludge Submitted by Plant C ..
4-16
v
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LIST OF TABLES (CONTINUED)
Table 4-7
Table 4-8
Table 4-9
Table 5-1
Table 5-2
Table 5-3
Table 7-1
Page No.
Treatment Performance Data for Stabilization of
K106 Collected by EPA at Plant D 4-17
Treatment Performance Data for Stabilization of D009
(Contaminated Soil and Debris from Natural Gas
Pipeline Industry) 4-19
Performance Data for Sulfide Precipitation Treatment
of K071 Wastewaters Collected by EPA at Plant E
Summary of Accuracy Adjustment of Treatment Data for
Total Mercury Generated from Thermal Recovery
Technologies
Mercury Compounds Known to be Present in Listed
Mercury Wastes and Their Melting Points, Boiling
Points, and Behavior
Summary of Accuracy Adjustment of Treatment Data for
Total Mercury in Wastewaters
Calculation of Numerical Treatment Standard for K106,
P065, P092, and U151 Wastewaters
4-20
5-15
5-17
5-18
7-10
7-11
BOAT Treatment Standard for K106, P065, P092,
and U151 Wastewaters
BOAT Treatment Standard for D009 Wastewaters
7-22
7-23
Table 7-2 Calculation of Numerical Treatment Standard for
Table 7-3
Table 7-4
Table 7-5-A BOAT Treatment Standard for K106 and U151 [All non-
wastewaters in the High-Mercury Subcategory (i.e.,
greater than or equal to 260 mg/kg total mercury)] ... 7-24
Table 7-5-B BOAT Treatment Standard for K106 and U151 [Non-
wastewaters that are residues from RMERC and are in
the Low-Mercury Subcategory (i.e., less than
260 mg/kg total mercury)] 7-25
vi
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LIST OF TABLES (CONTINUED)
Page No.
Table 7-5-C BOAT Treatment Standard for K106 and U151 [Non-
wastewaters that are residues from RMERC and are in
the Low-Mercury Subcategory (i.e., less than
260 mg/kg total mercury) ] 7-26
Table 7-6-A BOAT Treatment Standard for P065 [All nonwastewaters
that are not incinerated residues and are not residues
from RMERC, regardless of mercury content 7-27
Table 7-6-B BOAT Treatment Standard for P092 [All nonwastewaters
that are not incinerator residues and are not residues
from RMERC, regardless of mercury content] 7-28
Table 7-6-C BOAT Treatment Standard for P065 and P092 [Nonwaste-
waters that are either incinerator residues or
residues from RMERC, and are in the High-Mercury
Subcategory (i.e., greater than or equal to 260 mg/kg
total mercury) ] 7-29
Table 7-6-D BOAT Treatment Standard for P065 and P092 [Nonwaste-
waters that are incinerator residues (and are not
residues from RMERC) that are also in the Low-Mercury
Subcategory (i.e., less than 260 mg/kg total mercury)]. 7-30
Table 7-6-E BDAT Treatment Standard for P065 and P092 [Nonwaste-
waters that are residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg
total mercury) ] 7-31
Table 7-7-A BDAT Treatment Standard for D009 [All nonwastewaters
that contain mercury and organics (and are not
incinerator residues) and are also in the High-Mercury
Subcategory (i.e., greater than or equal to 260 mg/kg
total mercury) ] 7-32
Table 7-7-B BDAT Treatment Standard for D009 [All nonwastewaters
that are inorganics (including incinerator residues
and residues from RMERC) and are in High-Mercury
Subcategory (i.e., greater than or equal to 260 mg/kg
total mercury) ] 7-33
VII
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LIST OF TABLES (CONTINUED)
Page No.
Table 7-7-C BDAT Treatment Standard for D009 [All nonwastewaters
in the Low-Mercury Subcategory (i.e., less than
260 mg/kg total mercury)] 7-34
Table 7-8
Table 7-9
A-2
BDAT Treatment Standard for D009 and U151 Elemental
Mercury Contaminated with Radioactive Materials 7-35
BDAT Treatment Standard for D009 Hydraulic Oil
Contaminated with Mercury and Radioactive Materials .
Table A-l Analytical Methods for K071 Wastewaters
Table
Procedures or Equipment Used in Mercury Analysis When
Alternatives or Equivalents Are Allowed in the
SW-846 Methods
Table A-3 Matrix Spike Recoveries Used to Correct Analytical
Data for K071 Mercury-Containing Wastewaters and
Nonwastewaters
Table B-l Principal Compounds of Mercury
7-36
A-2
A-3
A-4
B-2
Vlll
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LIST OF FIGURES
Page No.
Figure 2-1 Mercury Chemicals and Primary Uses 2-3
Figure 2-2 Processes Generating K071 and K106 Wastes 2-10
IX
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1. INTRODUCTION AND SUMMARY
Pursuant to section 3004(m) of the Resource Conservation and Recovery
Act (RCRA), enacted as a part of the Hazardous and Solid Waste Amendments
(HSWA) on November 8, 1984, the Environmental Protection Agency (EPA) is
establishing treatment standards based on best demonstrated available
technology (BOAT) for the following: mercury-containing waste identified
in 40 CFR 261.32 as K106; specific mercury commercial chemical product-
containing wastes identified in 40 CFR 261.33 as P065, P092, and U151;
and wastes identified in 40 CFR 261.24 as D009 exhibiting the
characteristic of TCLP toxicity for mercury (see 54 FR 11798, March 29,
1990, which replaces the existing EP leach test with the TCLP for all
hazardous wastes listed under 40 CFR 261.24). Compliance with these
treatment standards is a prerequisite for the placement of these wastes
in facilities designated as land disposal units according to 40 CFR
Part 268. The effective date of final promulgated treatment standards
for these wastes is August 8, 1990.
This background document presents the Agency's rationale and
technical support for developing regulatory treatment standards for the
mercury-containing wastes identified above. Section 2 describes the
potential industries affected by regulation of these wastes, explains the
potential processes generating these wastes, and presents available waste
characterization data. There may be other industrial operations not
addressed in Section 2 that may generate wastes meeting the criteria for
mercury hazardous wastes under 40 CFR Part 261. If so, these other
wastes are also subject to the restrictions EPA is promulgating today
under 40 CFR Part 268. Section 3 specifies the applicable and
demonstrated treatment technologies for these wastes. Section 4 contains
performance data for the demonstrated technologies, and Section 5
analyzes these performance data to determine BOAT for each waste.
Section 6 presents the rationale for selection of regulated constituents,
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and Section 7 presents the BOAT treatment standards and their calculation
for the regulated constituents selected for each waste.
EPA's promulgated methodology for developing BDAT treatment standards
is described in two separate documents: Generic Quality Assurance
Project Plan for Land Disposal Restrictions Program ("BDAT") (USEPA
1988a) and Methodology for Developing BDAT Treatment Standards (USEPA
1989a). Facilities unable to meet the treatment standards can petition
the Administrator for a variance from the treatment standards. The
petition process to be followed in requesting a variance from the BDAT
treatment standards and the information required are discussed in the
methodology document.
The Agency classifies hazardous wastes as either wastewaters or
nonwastewaters. For the purpose of determining the applicability of the
treatment standards, wastewaters are defined as wastes containing less
*fc
than 1 percent (weight basis) total suspended solids and less than 1
percent (weight basis) total organic carbon (TOC). Wastes not meeting
this definition must comply with the treatment standards for
nonwastewaters.
For all wastewater forms of K106, P065, P092, and U151, EPA is
promulgating a treatment standard of 0.030 mg/1. The treatment standard
is based on the performance of sulfide precipitation treatment of K071
wastewaters. Some mercury-containing wastewaters may require additional
or different treatment trains in order to treat other metals or organics
* 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°C to 105°C) in Standard
Methods for the Examination of Water and Wastewater, 15th Edition
(APHA, AWWA, and WPCF 1985).
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that may interfere with the treatment of mercury. Pretreatment by an
oxidation step (with reagents such as hydrogen peroxide or sodium
hypochlorite) or incineration may be necessary to treat the organics in
P092 wastewaters. Pretreatment by aqueous chemical deactivation or by
incineration in specially-designed thermal treatment units may be
necessary to treat reactive constituents in P065 wastewaters. The
treatment standard for K106, P065, P092, and U151 wastewaters is
presented in Table 1-1, at the end of this section.
For D009 wastewaters, EPA proposed two regulatory options. One
regulatory option would have required treatment of these wastes to comply
with a treatment standard of 0.030 mg/1. The second regulatory option
was to require treatment of these wastes to meet a treatment level of
0.20 mg/1 (the toxic characteristic level for mercury). In the proposed
rule, EPA solicited comments on the merits of each of these approaches.
The Agency received many comments and reviewed each carefully before
deciding to regulate D009 wastewaters at the characteristic level of
0.20 mg/1. Even though the data available to EPA indicate that a
treatment standard of 0.030 mg/1 is achievable for many D009 wastewaters,
EPA is adopting the characteristic level of 0.20 mg/1 as the treatment
standard for D009 wastes for reasons outlined in Section II1.D of today's
final rule for Third Third wastes. In addition, available data indicate
that even the most difficult to treat D009 wastewaters can be treated to
the characteristic level of 0.20 mg/1. The treatment standard for D009
wastewaters is presented in Table 1-2.
For nonwastewater forms of K106, U151, P065, P092, and D009, EPA is
establishing two general mercury subcategories: a High-Mercury Subcate-
gory and a Low-Mercury Subcategory. A total mercury concentration of
260 mg/kg has been established to classify these mercury wastes into one
of these two subcategories and to determine compliance with the treatment
1-3
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standards. The 260 mg/kg cutoff level is based on the mercury
concentrations of an untreated mixed K071/K106 waste being
retorted/roasted. (See Section 7 for a detailed explanation of the
derivation of the 260 mg/kg cutoff level.)
Also, the Agency is setting additional restrictions for the disposal
of treatment residues resulting from incinerators, retorters, or
roasters. These additional restrictions are expressed as a requirement
for further treatment (e.g., further retorting) or a requirement for
compliance with a maximum concentration of leachable mercury acceptable
for disposal (e.g., TCLP mercury leachate below 0.20 mg/1 for residues
from retorters and roasters). EPA believes these additional requirements
will adequately minimize the commenters' concern of having a more
leachable mercury in incinerated, retorted, or roasted wastes. The
Agency's authority to impose these additional conditions comes directly
under Section 3004(m).
For nonwastewater forms of K106 and U151 in the high-mercury
subcategory, EPA is promulgating a treatment standard of retorting/
roasting. Nonwastewater residues from retorting/roasting are not
prohibited from land disposal unless they leach mercury above 0.20 mg/1,
as measured by TCLP. Nonwastewater residues unacceptable for land
disposal (i.e., those that leach mercury at levels exceeding 0.20 mg/1)
are required to comply with the appropriate standards (i.e., high- or
low-mercury subcategory) as a prerequisite for land disposal. It is
impermissible to dilute a High Mercury Subcategory waste to reduce the
concentration to less than 260 mg/kg.
For nonwastewater forms of K106 and U151 that are not residues from
retorting/roasting and are in the Low-Mercury Subcategory, EPA is
transferring the performance of acid leaching treatment followed by
sulfide chemical precipitation of K071 nonwastewaters to these inorganic
1-4
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mercury nonwastewaters. The BOAT treatment standard for these wastes is
0.025 mg/1 mercury as measured by the TCLP leachate. Residues from this
acid leaching process must be evaluated for mercury content to determine
whether they must undergo roasting/retorting. Treatment standards for
K106 and U151 nonwastewaters are summarized in Tables 1-3-A, 1-3-B, and
1-3-C.
The Agency proposed creating a new subcategory for K071
nonwastewaters identified as the K071 High-Mercury Subcategory (greater
than or equal to 16 rag/kg total mercury). For K071 nonwastewaters in the
High-Mercury Subcategory, the proposed treatment standard was retorting
or roasting as a method of treatment. EPA received several comments on
this proposed revision and has decided, upon further review, not to adopt
the proposed revisions. The existing BOAT standard for K071
nonwastewaters is retained (53 FR 31166). However, this decision does
not preclude the Agency from revising the treatment standard in the
future if new data become available.
For P065 and P092 nonwastewaters, the BOAT treatment standard is
incineration for the carbon-mercury compounds. Alternatively, EPA is
promulgating retorting or roasting for P092 nonwastewater. Incinerator
nonwastewater residues equal to or above 260 mg/kg mercury are considered
to be in the High-Mercury Subcategory and must be recovered by retorting
or roasting. Incinerator nonwastewater residues below 260 mg/kg are
considered to belong to the Low-Mercury Subcategory and are not
prohibited from land disposal unless they leach mercury above 0.025 mg/1
(as measured by the TCLP). Nonwastewater residues from retorting/
roasting operations are not prohibited from land disposal unless they
leach mercury equal to or above 0.20 mg/1 (as measured by the TCLP).
Retorting/roasting residues unacceptable for land disposal (i.e., above
0.20 mg/1) are required to comply with the applicable standards for the
High- or Low-Mercury Subcategory. P065 and P092 scrubber waters
generated from incineration, roasting, or retorting must comply with the
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0.030 mg/1 wastewater standard (see Table 1-1), which is based on the
same performance data used to develop the existing K071 wastewater
standard. Treatment standards for P065 and P092 nonwastewaters are shown
in Tables 1-4-A through 1-4-E.
The BDAT treatment standard for D009 High-Mercury Subcategory
nonwastewaters (i.e., those that contain greater than or equal to
260 mg/kg of mercury) is a combination of the treatment standards for the
high-mercury inorganic nonwastewaters and the organic mercury
nonwastewaters. EPA has determined that retorting or roasting represents
BDAT for D009 high-mercury nonwastewaters containing elemental mercury or
inorganic mercury compounds. Although D009 wastes that contain
organomercury constituents or that contain mercury contaminated with
organics can also be retorted/roasted, a pretreatment step may be
necessary to allow recovery of mercury. Incineration has been determined
to be BDAT for organics in this type of D009 nonwastewater and also for
nonwastewater containing organomercury constituents. Since incineration
cannot destroy mercury, but instead concentrates mercury in scrubber
water or ash to levels not expected to be acceptable for land disposal,
the Agency has established additional requirements for the mercury in
these residuals. As a result, the treatment standard for D009
high-mercury nonwastewaters is expressed as either retorting/roasting or
incineration. Incinerator nonwastewater residues that contain concentra-
tions of mercury greater than or equal to 260 mg/kg are considered to
belong to the High-Mercury Subcategory and must be retorted/roasted prior
to disposal. Nonwastewater residues from retorting/roasting operations
are not prohibited from land disposal unless they leach mercury above
0.20 mg/1 (as measured by the TCLP). Retorting/roasting residues
unacceptable for disposal (i.e., above 0.20 mg/1 TCLP) are required to
comply with the appropriate standards for the D009 High- or Low-Mercury
Subcategory.
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For D009 low-mercury nonwastewaters, EPA is promulgating a treatment
standard of 0.20 mg/1, as measured by TCLP (i.e., the toxic
characteristic level for mercury). EPA received very few data on the
proposed standards for D009 wastes. These data were determined to
represent the treatment of mercury-containing wastes failing the listing
criteria for D009, as measured by TCLP. However, several commenters
supported the regulatory alternative for setting treatment standards for
D009 wastes at the characteristic level. Although data available to EPA
indicate that the lower proposed standard (0.025 mg/1) should be
achievable for D009, EPA acknowledges the commenters' concerns that a
large, diverse number of wastes that qualify as D009 may not be
represented by K071 performance data. EPA is thus in withdrawing the
proposed 0.025 mg/1 level (based on K071 performance data). Based on the
available data, EPA believes D009 wastes can be treated to the
characteristic level by treatment technologies such as stabilization or
amalgamation with zinc or tin. EPA is instead promulgating a treatment
standard of 0.20 mg/1 mercury, as measured by TCLP, for these nonmercury
nonwastewaters. BOAT treatment standards for D009 nonwastewaters are
summarized in Tables 1-5-A, 1-5-B, and 1-5-C.
Several commenters identified a list of D009 wastes that the
commenters believe meet EPA's criteria for contaminated soil and debris.
The commenters believe that these D009 wastes are not amenable to
retorting/roasting; however, they have proposed alternative treatment
standards based on the use of a chemical decontamination technology. EPA
has been unable to determine whether the alternative chemical
decontamination technology represents BOAT for these wastes. The Agency
believes such demonstration can be made as part of the ongoing regulatory
efforts for contaminated soil and debris. If the technology is
demonstrated, EPA may publish revisions to today's standards for these
wastes.
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Information provided to EPA by the U.S. Department of Energy (DOE)
indicates the generation of two particular D009 mixed radioactive/
hazardous wastes that contain mercury. This information also suggests
that the BOAT technologies and standards for the corresponding
nonradioactive wastes may not be applicable to these mixed wastes. The
Agency has therefore promulgated alternative treatment standards for
these wastes.
One of the mixed wastes identified is waste elemental mercury
contaminated with radioactive tritium (a radioisotope of hydrogen).
These wastes are often identified as D009 or U151. EPA has determined
that recovery technologies do not represent BOAT for this waste because
the Agency lacks data indicating that these processes would be able to
separate the mercury from the radioactive material, resulting in recovery
of reusable mercury. EPA has identified amalgamation with zinc as a
technology that provides significant treatment to these wastes in terms
of air emissions (thus greatly reducing the toxicity of these wastes) and
also potentially reduces the leachability of mercury by amalgamation.
The BOAT for these wastes is amalgamation with zinc, and the treatment
standard is amalgamation with zinc as a method of treatment.
The second mixed waste identified is a spent hydraulic oil
contaminated with mercury and radioactive tritium. EPA determined that
incineration represents BOAT for this waste because incineration is
demonstrated for nonradioactive organic mercury nonwastewaters. However,
the Agency has modified the nonradioactive organic mercury nonwastewaters
standard for this waste by withdrawing the requirement to recover mercury
from the inorganic residues generated from incineration of this waste.
The Agency is requiring that nonwastewater incineration residues
(incinerator ash and wastewater treatment sludge generated from treatment
of incineration scrubber waters) comply with a TCLP mercury standard of
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0.20 mg/1 and that incineration scrubber waters meet the 0.20 mg/1 total
concentration mercury standard for mercury-containing wastewaters.
Treatment standards for mixed radioactive/hazardous mercury wastes are
presented in Tables 1-6-A and 1-6-B.
EPA is specifying further that, for treatment standards expressed as
methods of treatment, certain regulatory conditions must be met.
Incinerators must be operated in accordance with the provisions under 40
CFR Part 264, Subpart 0, or Part 265, Subpart 0. Also, EPA is specifying
that, as part of the BDAT, the retorting/roasting unit (or facility) must
be subject to one or more of the following: (1) NESHAP for mercury,
(2) a PDS permit, or (3) a State permit that establishes emission
limitations pursuant to Section 302 of the Clean Air Act for mercury.
The Agency believes that with such air emission controls retorting
is a treatment technology that minimizes threats to human health and the
environment and so satisfies the requirements of section 3004(m). (The
Agency's authority to impose these conditions on performance of a mercury
retorting device comes directly from its authority under section 3004(m)
to establish methods of treatment. EPA is indicating here that part of
the designated method includes operating pursuant to standards that
prevent cross-media contamination. Such standards are enforceable under
RCRA pursuant to the authority in section 3008(a).)
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Table 1-1 BOAT Treatment Standard for K106,
P065, P092, and U151 Wastewaters
Maximum for any single grab sample
Total composition
Regulated constituent (mg/1)
Mercury 0.030
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Table 1-2 BOAT Treatment Standard for D009 Wastewaters
Maximum for anv single grab sample
Total composition
Regulated constituent (mg/1)
Mercury 0.20
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Table 1-3-A BOAT Treatment Standard for K106 and U151
[All nonwastewaters in the High-Mercury
Subcategory (i.e., greater than or equal to
260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be subject
to one or more of the following: (a) a National Emissions Standard for
Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best Available Control
Technology (BACT) or a Lowest Achievable Emission Rate (LAER) standard for
mercury imposed pursuant to a Prevention of Significant Deterioration (PSD)
permit; or (c) a State permit that establishes emission limitations (within
meaning of Section 302 of the Clean air Act) for mercury. All wastewater
and nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration of
any applicable subcategories (e.g., High- or Low-Mercury Subcategories).
1-12
2861g
-------
Table 1-3-B BOAT Treatment Standard for K106 and U151
[Nonwastewaters that are residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg total mercury)]
Regulated Maximum for any single grab sample
constituent TCLP (mg/1)
Mercury 0.20
1-13
2861g
-------
Table 1-3-C BDAT Treatment Standard for K106 and U151
[Nonwastewaters that are not residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg total mercury)]
Regulated Maximum for anv single Erab sample
constituent TCLP (mg/1)
Mercury 0.025
1-14
2861g
-------
Table 1-4-A BOAT Treatment Standard for P065
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of mercury content]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
a(IMERC) incineration of wastes containing organics and mercury in units
operated in accordance with the technical operating requirements of 40
CFR 264 Subpart 0 and 265 Subpart 0). All wastewater and nonwastewater
residues derived from this process must then comply with the
corresponding treatment standards per waste code with consideration of
any applicable subcategories (i.e., High- or Low-Mercury Subcategories.)
1-15
2861g
-------
Table 1-4-B BDAT Treatment Standard for P092
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of mercury content]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
OR ROASTING/RETORTING (RMERC)b
a(IMERC) incineration of wastes containing organics and mercury in units
operated in accordance with the technical operating requirements of 40
CFR 264 Subpart 0 and 265 Subpart 0). All wastewater and nonwastewater
residues derived from this process must then comply with the
corresponding treatment standards per waste code with consideration of
any applicable subcategories (i.e., High- or Low-Mercury Subcategories.)
(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be
subject to one or more of the following: (a) a National Emissions
Standard for Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best
Available Control Technology (BACT) or a Lowest Achievable Emission Rate
(LAER) standard for mercury imposed pursuant to a Prevention of
Significant Deterioration (PSD) permit; or (c) a State permit that
establishes emission limitations (within meaning of Section 302 of the
Clean Air Act) for mercury. All wastewater and nonwastewater residues
derived from this process must then comply with the corresponding
treatment standards per waste code with consideration of any applicable
subcategories (e.g., High- or Low-Mercury Subcategories).
1-16
2861g
-------
Table 1-4-C BOAT Treatment Standard for P065 and P092
[Nonwastewaters that are either incinerator residues or residues
from RMERC, and are in the High-Mercury Subcategory (i.e., greater
than or equal to 260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be
subject to one or more of the following: (a) a National Emissions
Standard for Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best
Available Control Technology (BACT) or a Lowest Achievable Emission Rate
(LAER) standard for mercury imposed pursuant to a Prevention of
Significant Deterioration (PSD) permit; or (c) a State permit that
establishes emission limitations (within meaning of Section 302 of the
Clean air Act) for mercury. All wastewater and nonwastewater residues
derived from this process must then comply with the corresponding
treatment standards per waste code with consideration of any applicable
subcategories (e.g., High- or Low-Mercury Subcategories).
1-17
286 lg
-------
Table 1-4-D BDAT Treatment Standard for P065 and P092
[Nonwastewaters that are incinerator residues (and are not
residues from RMERC) that are also in the Low-Mercury Subcategory
(i.e., less than 260 mg/kg total mercury)]
Maximum for any single grab sample
TCLP
Regulated constituent (mg/1)
Mercury 0.025
1-18
2861g
-------
Table 1-4-E BOAT Treatment Standard for P065 and P092
[Nonwastewaters that are residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg total mercury)]
Maximum for any single grab sample
TCLP
Regulated constituent (mg/1)
Mercury 0.20
1-19
2861g
-------
Table 1-5-A BDAT Treatment Standard for D009
[All nonwastewaters that contain mercury and organics (and are not
incinerator residues) and are also in the High-Mercury Subcategory
(i.e., greater than or equal to 260 mg/kg total mercury)]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
OR ROASTING/RETORTING (RMERC)b
a(IMERC) incineration of wastes containing organics and mercury in
units operated in accordance with the technical operating requirements
of 40 CFR 264 Subpart 0 and 265 Subpart 0. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury Subcate-
gories.)
(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized
mercury for recovery. The retorting or roasting unit (or facility)
must be subject to one or more of the following: (a) a National
Emissions Standard for Hazardous Air Pollutants (NESHAP) for mercury;
(b) a Best Available Control Technology (BACT) or a Lowest Achievable
Emission Rate (LAER) standard for mercury imposed pursuant to a
Prevention of Significant Deterioration (PSD) permit; or (c) a State
permit that established emission limitations (within meaning of Section
302 of the Clean Air Act) for mercury. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury Subcate-
gories) .
1-20
2861g
-------
Table 1-5-B BOAT Treatment Standard for D009
[All nonwastewaters that are inorganics (including incinerator residues
and residues from RMERC) and are in the High-Mercury Subcategory
(i.e., greater than or equal to 260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized
mercury for recovery. The retorting or roasting unit (or facility)
must be subject to one or more of the following: (a) a National
Emissions Standard for Hazardous Air Pollutants (NESHAP) for mercury;
(b) a Best Available Control Technology (BACT) or a Lowest Achievable
Emission Rate (LAER) standard for mercury imposed pursuant to a
Prevention of Significant Deterioration (PSD) permit; or (c) a State
permit that established emission limitations (within meaning of Section
302 of the Clean Air Act) for mercury. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury Subcate-
gories).
1-21
2861g
-------
Table 1-5-C BOAT Treatment Standard for D009
[All nonwastewaters in the Low-Mercury Subcategory
(i.e., less than 260 mg/kg total mercury)]
Regulated Maximum for any single grab sample
constituent TCLP (rag/1)
Mercury 0.20
1-22
2861g
-------
Table 1-6-A BOAT Treatment Standard for D009 and U151
Elemental Mercury Contaminated with Radioactive Materials
AMALGAMATION WITH ZINC AS A METHOD OF TREATMENT FOR NONWASTEWATERS3
aAny wastewaters must comply with the appropriate wastewater standard
(for D009 or U151).
1-23
2861g
-------
Table 1-6-B BOAT Treatment Standard for D009 Hydraulic Oil
Contaminated with Mercury and Radioactive Materials
INCINERATION AS A METHOD OF TREATMENT WITH INCINERATOR RESIDUES
MEETING 0.20 MG/L, AS MEASURED BY THE TCLP
1-24
2861g
-------
2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION
As discussed in Section 1, those wastes listed in 40 CFR 261.24,
261.32, and 261.33 are subject to the land disposal restriction
provisions of RCRA. This document discusses the mercury-containing
wastes K106, P065, P092, U151, and D009. This section describes the
potential industries affected by land disposal restrictions for these
mercury-containing wastes and the potential processes generating the
wastes, summarizes available waste characterization data, and discusses
applicable treatability groups. Other operations may be generating
mercury wastes not covered in this section. However, if their wastes
meet any of the descriptions in 40 CFR 261.44, 261.32, and 261.33, their
wastes may also be subject to the land disposal restrictions in 40 CFR
Part 268.
Within the industry-specific listing of hazardous wastes in Section
261.32 are the following three wastes generated by the chlorine industry:
K071: Brine purification muds from the mercury cell process in
chlorine production, where separately prepurified brine is not
used.
K073: Chlorinated hydrocarbon waste from the purification step of
the diaphragm cell process using graphite anodes in chlorine
production.
K106: Wastewater treatment sludge from the mercury cell process in
chlorine production.
The listed waste K071 was regulated previously with the First Third
restricted wastes (USEPA 1988b). Although nonwastewater treatment
standards for this waste were proposed for revision under the Third Third
rule, EPA has decided to retain the existing standards and not to adopt
the proposed revisions. The listed waste K071 is discussed in a separate
First Third background document (USEPA 1988b). The listed waste K073 is
discussed in a separate Third Third background document (USEPA 1989c).
2-1
2862g
-------
This background document addresses the development of treatment standards
for K106.
The following wastes are listed in 40 CFR Section 261.33 for mercury:
P065: Mercury fulminate
P092: Pheny liner curie acetate
U151: Mercury
The U and P wastes of concern (U151, P065, and P092) are generated as
discarded chemical products, off-specification products, container
residues, or contaminated soil, water, or other debris resulting from the
cleanup of leaks or spills of products or off-specification products.
This background document addresses the development of treatment standards
for P065, P092, and U151.
This document also discusses the development of treatment standards
for wastes listed in 40 CFR 261.24 as D009. D009 is any waste that is
characteristically hazardous based on the concentration of mercury in the
leachate as determined by the Toxicity Characteristic Leaching Procedure
(TCLP)(see 54 FR 11798, March 29, 1990). D009 wastes can be generated in
many different forms by many different industrial processes.
2.1 Industries Affected and Process Descriptions
Metallic mercury and inorganic and organic mercury compounds are used
in many industries. Figure 2-1 summarizes the major manufacturing
process chemistry and end uses of mercury compounds. Table 2-1 presents
the major industrial end users of mercury listed in decreasing order of
their mercury consumption in 1983.
The largest use of mercury, amounting to 48 percent of all mercury
used in 1983 (the last year for which statistics were available) is in
2-2
2862g
-------
MERCURY BUTTER (MERCURY/IRON AMALGAM) IN SOME
MEPOURY CELL BATTERIES
CHLOB-ALKAU MERCURY CELL ELECTRODES.
INDUSTRIAL AND CONTROL INSTRUMENTS.
MERCURY VAPOR LAMPS
WIRING AND SWITCHING DEVICES • ELECTRICAL CONNECTIONS
MERCURY FULMINATE
Hg(OCNL
USED AS A PRIMARY
EXPLOSIVE (DETONATOR).
MADE INTO CAPS; NOT
TRANSPORTED OR SOLD
AS THE PURE COMPOUND
BECAUSE IT IS EXPLOSIVE.
MERCURIC OXIDE
BATTERIES (RED)
(PRIMARY ZINC/CARBON
CELL AND OTHERS)
•HCjH,02
(ACETIC ACID)
CATALYSTS, LABORATORY
USES. PHARMACEUTICALS
INORGANIC
ORGANIC
*ACETIC ACID
BENZENE
PHENVLMERCURIC
ORGANOMERCURY
PHENYLMERCURIC
(MERTHIOLATE)
ROPYUIERCURIC
MERCUROCHROME
PHENVLMERCURIC
PAINT FUNGICIDE
AND BACTERICIDE
(LATEX PAINTS)
ANTISEPTIC PHARMACEUTICALS
FIGURE 2-1. MERCURY CHEMICALS AND PRIMARY USES
2-3
-------
Table 2-1 Major Industrial Uses of Mercury
Industry
SIC Codes
Amount of
mercury used
(thousands of Ib)
Electrical products
(batteries, lamps, wiring
and switching devices, etc.)
3600
2,050
Chlorine production
Paints
Instruments
( thermometers , manometers ,
barometers, etc.)
Dental supplies
Catalysts, miscellaneous
Other
(Pharmaceuticals, pigments,
lab analyses , etc . )
2812
2851
3820
3843
2819, 2869
2833, 2816,
others
612
460
187
121
37
270
Source: U.S. Bureau of Mines 1985.
2-4
2862g
-------
the manufacture of mercuric oxide batteries, primarily the mercuric
oxide/zinc dry cell. Mercuric oxide is used as the cathode material in
these batteries. Metallic mercury is often amalgamated with other metals
(e.g., silver and zinc) and used as the anode material in batteries. The
production of batteries using mercury and mercuric oxide is discussed in
Section 2.1.1.
The second largest use of mercury, amounting to 16 percent of that
used in 1983, is in the manufacture of chlorine by the mercury cell
process. Metallic mercury is used in this process as the cathode
material in electrolytic cells that decompose a sodium chloride brine
solution into sodium hydroxide and chlorine. This process is discussed
in Section 2.1.2.
The next largest use of mercury is as a fungicide and bactericide in
latex paints. The primary compound used in this application is
phenylmercuric acetate. Other organic mercury compounds are also used.
Phenylmercuric acetate is made from mercuric acetate, as shown in
Figure 2-1.
Other uses of mercury metal are in electrical equipment such as
industrial control instruments, in mercury vapor lamps, in wiring and
switching devices as an electrical connection, and in barometers and
thermometers. Mercury compounds are also used as initiating explosives
(mercury fulminate), as homogeneous catalysts (mercuric chloride), as
components of agricultural fungicides (mercurous chloride and mercuric
chloride), and as antiseptic Pharmaceuticals (various organic and
inorganic mercury compounds).
2.1.1 Manufacture of Mercury Batteries
Many batteries contain metallic mercury or mercuric oxide as
components. Mercury cell batteries (mercuric oxide:zinc cells) consist
2-5
2862g
-------
of a mercuric oxide powder as the cathode, a mercury/zinc amalgam as the
anode, and an alkaline electrolyte solution (usually potassium
hydroxide). Mercuric oxide is also used in other types of batteries as a
cathode material. Both nonwastewaters and wastewaters containing mercury
can be generated from battery manufacturing. Wastewaters containing
mercury can be generated from cleanup of spills of mercuric oxide or
metallic mercury or as water washes of processing equipment.
Nonwastewaters that can be generated include off-specification batteries,
spilled or off-specification mercuric oxide, spilled mercury, or
wastewater treatment sludges generated from the treatment of
mercury-containing wastewaters.
2.1.2 Chlorine Production by the Mercury Cell Process
Chlorine is produced primarily from the electrolytic decomposition of
either sodium chloride or potassium chloride, from which the coproducts
are sodium hydroxide (caustic soda) or potassium hydroxide. All of the
caustic soda and potassium hydroxide and over 90 percent of the chlorine
produced in the United States are made by the electrolytic decomposition
of sodium chloride or potassium chloride. Chlorine is also produced by
other processes, including nonelectrolytic oxidation of hydrochloric acid
(HC1), the production of sodium metal, and the electrolytic production of
magnesium metal from molten magnesium chloride.
Three types of electrolytic cells are in commercial use for the
production of alkalies and chlorine: the mercury cell, the diaphragm
cell, and the membrane cell. The listed waste K106 is generated in
chlorine production by the mercury cell process. The Agency estimates
that there are 20 facilities that produce chlorine by the mercury cell
process and may generate K106 waste. EPA also estimates that 14 of these
facilities do not use prepurified salt and thus also may generate K071
waste. The locations of these facilities are provided in Table 2-2,
2-6
2852%
-------
Table 2-2 Number of Producers of Chlorine Using the
Mercury Cell Process Listed by State
Number of Number that do not
State (EPA Region) producers use prepurified salt
Alabama (IV) 3 3
Delaware (III) 1 1
Georgia (IV) 2 1
Kentucky (IV) 1 1
Louisiana (VI) 2 1
Maine (I) 1 1
New York (II) 2 1
North Carolina (IV) 1 1
Ohio (V) 1 1
Tennessee (IV) 1 1
Texas (VI) 1 0
Washington (X) 1 1
West Virginia (III) 2 0
Wisconsin (V) 1 1_
Total 20 14
Source: SRI 1989.
2-7
2862s
-------
listed by State, and in Table 2-3, listed by EPA Region. Chlorine
producers fall under SIC Code 2812, Alkalies and Chlorine.
In chlorine production by the mercury cell process, a saturated salt
brine solution is prepared by dissolving sodium chloride, usually in the
form of rock salt (although prepurified salt is sometimes used), in the
depleted brine solution recycled from the mercury cells (see
Figure 2-2). The brine is purified (unless prepurified salt is used) by
addition of sodium carbonate and sodium hydroxide to precipitate any
dissolved impurities. Solids (muds) generated in brine purification are
the listed waste K071. The purified saturated brine is fed to the
mercury cells, where electrolytic decomposition into sodium hydroxide and
chlorine occurs. The chlorine is subsequently purified. If potassium
chloride is used as a feed to the process, potassium hydroxide and
chlorine are produced.
Sources of wastewater from the production of chlorine by the mercury
cell process include (1) brine that is bled from the end boxes of the
mercury cells; (2) wastewater collected from the floor of or basement
below the room containing the mercury cells, generated from periodic
washdown of the cell room floor and equipment; and (3) any other
wastewaters generated by the plant that may contain mercury. Treatment
of plant process wastewaters by chemical precipitation generates a
wastewater treatment sludge, which is the listed waste K106.
With the exception of one mercury cell chlorine production facility, K106
is generated by sulfide precipitation. One facility currently uses
hydrazine to treat mercury-contaminated wastewaters; this process
generates a mercurous hydroxide compound. In the past, K106 was
generated by chemical reduction treatment of mercury-contaminated
wastewaters using sodium borohydride. EPA is uncertain whether sodium
borohydride is still used to treat mercury-contaminated wastewaters.
2-8
28626
-------
Table 2-3 Number of Producers of Chlorine Using the Mercury
Cell Process Listed by EPA Region
Number of Number that do not
EPA Region producers use prepurified salt
I 11
II 21
III 3 1
IV 87
V 22
VI 31
X 1 __L
Total 20 14
Source: SRI 1989.
2-9
2862g
-------
PRODUCTION PROCESS
RECYCLED SPENT BRINE
ro
i
BRINE
FORTIFICATION
BRINE
PURIFICATION
I
BRINE
FILTERS
BRINE
PURIFICATION
MUDS
K071
ELECTROLYTIC
CELLS
PRODUCT
«2
_r \
Hfl
WATER
DENUDER
CELLS
Hfl-Ni
CO-PRODUCT
AMALGAfc
CO-PRODUCT
50% NaOH
SOLUTION
PURGED BRINE
WASTE TREATMENT PROCESSES
K071
i
K071 ACID
LEACHING
TREATMENT
PLANT RUNOFF
AND WASH DOWN
LEACHATE
WASTEWATER
TREATMENT
.TREATED
WASTEWATER
TREATED
K071
SOLIDS
WASTEWATER
TREATMENT
SLUDGE
K106
-------
2.1.3 Manufacture and Use of Organomercury Fungicides and Bactericides
The Agency has information that phenylmercuric acetate (P092) and
phenylmercuric oleate are produced by Cosan Chemical in Carlstadt, New
Jersey (SRI 1989). These compounds (and other phenylmercury compounds)
are used as bactericides in latex paint formulations. Phenylmercuric
acetate is manufactured by reaction of mercuric acetate with benzene.
Phenylmercuric acetate can be used as a starting material in the
production of many other phenylmercury compounds.
In paint formulation operations, pigments are mixed with solvents,
carriers, and other additives. Phenylmercury compounds are added in very
small quantities (less than 1 percent) as preservatives for latex
paints. Washing of equipment used in paint formulation may result in the
generation of wastes containing organomercury compounds such as
phenylmercuric acetate. These wastes sometimes contain other organic
compounds as well.
2.2 Waste Characterization
2.2.1 K106
EPA has waste characterization data for both K106 generated by
sulfide treatment and K106 generated by hydrazine treatment. The
approximate concentrations of the major constituents for both of these
K106 forms were determined from EPA analysis of the waste and other
characterization data and information submitted by industry to EPA. As
summarized in Table 2-4, both forms of K106 are primarily composed of
water and diatomaceous earth filter aid. The K106 generated by sulfide
precipitation contains approximately 4.4 percent mercury on average, as
mercuric sulfide; the K106 generated by hydrazine treatment contains
approximately 0.5 percent mercury on average, as mercurous hydroxide.
2-11
2862g
-------
3652g
Table 2-4 yaste Composition Data for Untreated K106 Wastes
Constituent
BOAT List Metals
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Other Analyses
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Potassium
Sodium
Tin
Sulfide
Total solids
Total suspended solids
Paint filter test
Diatomaceous earth
Water
Sodium chloride
Untreated K106 waste concentration
(a) (b) (c) (c) (c)
(mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg)
<3.8 - - - -
1.1 - - - -
74 - -
<0.1 - - - -
2.3 - -
6.3 - -
133 - -
50 - - -
25,900 2000 - 150,000 4300 - 17,000 55,000 - 146,000 5000 - 7000
14 - -
<5.0 - - -
131 - - -
<8.6 - - - -
0.46 - - - -
443 - - -
168 - - -
478 - - -
1.3 - - -
833 400 - -
132 - - -
6.5 - - -
7,870 - - - -
4,120 - - - -
<5.5 - - - -
.
41.5 - - -
-
Pass - - - -
700,000 - 950,000 800,000 - 950,000
5000 - 20.000 50.000 - 150,000
80,000 - 100,000
- = Not analyzed.
Sources: (a) USEPA 1988c.
(b) Versar 1986.
(c) USEPA 1985.
(d) The Chlorine Institute 1988.
2-12
-------
3652g
Table 2-4 (continued)
Constituent
BOAT List Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Other Analyses
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Potassium
Sodium
Tin
Sulfide
Total solids
Total suspended solids
Paint filter test
Diatomaceous earth
Water
Sodium chloride
Chloride
Sulfate
Total organic carbon
Oil and grease
- = Not analyzed.
Sources: (a) USEPA 198Bc.
(b) Versar 1986.
(c) USEPA 1985.
(d) The Chlorine
(d)
Total
(nig/kg)
<52
52
119
<1.4
15
223
861
456
62,500
138
1.7
12
-
9.0
3940
-
-
-
-
-
-
-
-
-
-
-
-
-
-
50,000
-
-
-
-
~
Institute 1988
Untreated
TCLP
(mg/kg)
0.175
<0.076
0.551
<0.004
0.03
0.128
<0.032
1.59
0.045
0.681
<0.05
<0.02
-
<0.016
15.2
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
K106 waste concentration
(d)
Total EP Toxicity
(mg/kg) (mg/kg)
-
0.7 0.003
6.0 0.06
2.3
2.3 0.03
4.6 0.024
-
Ill
0.006
1.0 0.045
0.3 0.001
2.8 0.0027
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
540.000
-
5910
3090
-
9.6
(d)
Total
(mg/kg)
<0.005
0.407
175
<1.5
5.0
36
345
135
38,300
260
<0.005
10
<5
<5
128
-
-
-
-
-
-
-
-
-
7,493
-
-
-
-
440,000
-
<60
5.0
-
4495
TCLP
(mg/kg)
<0.005
0.016
0.12
<0.005
<0.01
<0.01
0.07
0.05
2.73
<0.01
<0.005
<0.01
<0.05
<0.02
0.05
-
-
-
-
-
-
-
-
-
196
-
-
-
-
-
-
-
-
-
-
2-13
-------
3652g
Table 2-4 (continued)
Constituent
BOAT List Metals
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Other Analyses
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Potassium
Sodium
Tin
Sulfide
Total solids
Total suspended solids
Paint filter test
Diatomaceous earth
Water
Sodium chloride
Chloride
Sulfate
Total organic carbon
Oil and grease
- = Not analyzed.
Sources: (a) USEPA 1988c
(b) Versar 1986
(c) USEPA 1985.
(d)
Total
(mg/kg)
<6
6.0
71
<0.2
2.0
70
361
142
161,000
167
<2
4.0
<5
<4
405
-
-
-
-
-
-
-
-
-
1590
-
-
-
-
690.000
-
47.000
19.100
39.600
3400
Untreated K106 waste concentration
(d) (d)
TCLP Total EP Toxicity Total
(mg/kg) (mg/kg) (mg/kg) (mg/kg)
<0.06 - - 0.2
0.14 3.0 <0.005 0.1
0.21 5.0 <0.03 3.0
<0.002
<0.005 0.4 <0.005
<0.007 750 0.6 3.0
<0.03 - - 250
<0.05 4.0 <0.5 100
3.68 20.000 <0.0005 5.000
1.16 34 0.09 100
<0.05 4.0 <0.005
<0.005 1.0 <0.007
<0.05 - -
<0.04 - -
3.04 - - 250
.
.
.
.
-
.
-
-
.
1.2 <11
.
.
-
.
580.000 - 500.000
-
.
-
-
22.500
TCLP
(mg/kg)
-
0.01
2.5
-
0.01
0.01
-
0.25
5.0
-
0.05
0.1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
(d) The Chlorine Institute 1988.
2-14
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3652g
Table 2-4 (continued)
Untreated K106 waste concentration
Constituent (d) (d) id)
Total
(mg/kg)
TCLP
(mg/kg)
Total
(mg/kg)
EP Toxicity
(ing/kg)
Total
(mg/kg)
TCLP
(mg/kg)
BOAT List Metals
Antimony - - - - -
Arsenic - - - - - -
Barium - - - - -
Beryllium - - - -
Cadmium - - - -
Chromium - - - - - -
Copper - - - - -
Lead - - - - -
Mercury 28,347 0.399 4098 2.26 23.004 1.25
Nickel - - - -
Selenium - - - -
Silver - - - - -
Thallium - - - -
Vanadium - - - - - -
Zinc - - - - -
Other Analyses
Aluminum - - - -
Calcium
Cobalt - - - -
Iron - - - -
Magnesium - - - - -
Manganese - - - -
Potassium - - - - -
Sodium - - - - -
Tin - - ...
Sulfide - - - -
Total solids
Total suspended solids - - - - -
Paint filter test - - - - - -
Diatomaceous earth - - - - -
Water 290,000 - - 400,000
Sodium chloride - - - - -
Chloride - - - -
Sulfate - - - -
Total organic carbon - - - - -
Oil and grease - - -
- = Not analyzed.
Sources: (a) USEPA 1988c.
(b) Versar 1986.
(c) USEPA 1985.
(d) The Chlorine Institute 1988.
2-15
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3652g
Table 2-4 (continued)
Untreated K106 waste concentration
Constituent (d) (d)
Total TCLP Total EP Toxicity
(mg/kg) (mg/kg) (mg/kg) (mg/kg)
BOAT List Metals
Antimony - - - -
Arsenic <100 <0.005 - <0.1 0.55
Barium 1300 1.32 - 0.12
Beryllium - - -
Cadmium <100 <0.01 - <0.01 6.5
Chromium <100 <0.01 - 0.06 2.46
Copper - - - -
Lead 400 0.05 - <0.1 204
Mercury 10,100 0.113 25,000 0.08
Nickel - - - 89
Selenium <100 <0.005 - <0.1 90
Silver <100 <0.01 - <0.01 70
Thallium - -
Vanadium - - - -
Zinc - - -
Other Analyses
Aluminum - - -
Calcium - - - -
Cobalt - - -
Iron - - -
Magnesium - - -
Manganese - - -
Potassium - - - -
Sodium - - -
Tin - - ...
Sulfide <0.1 - <0.016 -
Total solids - - -
Total suspended solids
Paint filter test - - -
Diatomaceous earth - - -
Water 650,000 - - - 450,000
Sodium chloride - - -
Chloride - - -
Sulfate - - -
Total organic carbon - - - -
Oil and grease - - 1270
- = Not analyzed.
Sources: (a) USEPA 1988c.
(b) Versar 1986.
(c) USEPA 1985.
(d) The Chlorine Institute 1988.
(e) Oxychem 1989. Range of 35 reported values for hydrazine waste.
(d)
Total TCLP
(mg/kg) (mg/kg)
-
0.012
0.07
-
<0.1
<1
-
0.5
<0.1 2.600-32.000
1.0
-
<0.3
-
-
-
-
-
-
-
-
-
-
-
-
<1.0
-
-
-
-
-
-
-
-
-
2-16
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2.2.2 P065
The Agency does not have data or information on the characterization
of P065 wastes. Analysis of the 1986 National Survey of Treatment,
Storage, Disposal, and Recycling Facilities (TSDR Survey, USEPA 1986a)
and the 1986 National Survey of Hazardous Waste Generators (Generator
Survey, USEPA 1986b) data bases indicates that no facilities generated or
treated P065 wastes in 1986. As of 1984, the U.S. Army reported that
mercury fulminate is no longer used by the U.S. military as an initiating
explosive because of poor stability (U.S. Army 1984).
2.2.3 P092
The Agency has no data on the composition of P092 (phenylmercuric
acetate) wastes. However, EPA does have data from one manufacturer on
the composition of a D009 wastewater generated in production of this
chemical. Characterization data for this D009 waste are presented in
Table 2-5. EPA expects phenylmercuric acetate to be the primary or sole
constituent of P092 wastes.
2.2.4 U151
EPA has data from the Generator Survey on the composition of U151
wastes (USEPA 1986b). These data show that of the U151 wastes that are
reported as a single waste code (i.e., not mixed with other listed or
characteristic wastes), a majority have mercury concentrations greater
than 50 percent. EPA expects that the principal constituent of most U151
wastes is metallic mercury.
2.2.5 D009
Characterization data for D009 wastes generated in the organomercury
chemicals and battery manufacturing industries are presented in Table 2-5,
2-17
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2872g/p.
Table 2-5 Waste Composition Data for 0009 Wastes
Untreated D009 waste concentration (units)
(a) (b)
Total
Constituent (mg/1)
BOAT List Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury 100-1,000
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
BOAT List Orqanics
Total
(mg/kg)
<2.4
<1.0
0.36
<0.1
<0.5
4.8
2.1
<0.5
974,000a
2.8
<0.5
1.1
<1.0
<0.4
<0.3
TCLP
(mg/1)
<0.024
<0.01
0.006
<0.001
<0.005
<0.004
0.024
0.016
1,490
<0.01
<0.005
<0.003
<0.01
<0.004
0.032
(c)
Total
(mg/kg)
<2.4
<1.0
42
<0.1
6.8
5.0
73
6.6
27,200
11
<0.5
111
<1.0
0.67
29,600
TCLP
(mg/1)
<0.024
<0.01
1.1
<0.001
0.306
<0.004
0.128
0.062
1.83
0.116
<0.025
0.0047
<0.01
<0.004
627
Benzene
Toluene
50-1,000
0.01-100
Other Analyses
Total organic carbon
10,700
6.620
aThis value is high. The theoretical maximum concentration for pure mercuric oxide (HgO) is
926,000 mg/kg. It is very difficult to analyze such high concentrations of mercury
accurately on an instrument designed to detect mercury at ppb levels.
- = Not analyzed
Sources (a) Cosan Chemical Corporation 1989. Waste generated from manufacture of
phenylmercuric acetate.
(b) USEPA 1989d. Mercuric oxide waste from recycling of batteries.
(c) USEPA 1989d. Zinc/Mercury amalgam from battery manufacturing.
2-18
-------
EPA also has data from the Generator Survey on the composition of D009
wastes (USEPA 1986b). These data show that D009 wastes may contain
organic compounds (usually when mixed with solvent wastes). Also, some
wastes generated in the production of organomercury compounds for
fungicide/bactericide and pharmaceutical uses and generated in organic
chemicals and polymers manufacturing where mercuric chloride catalyst is
used may contain mercury in an organic waste matrix. Overall, the
mercury concentrations of D009 wastes (organic and inorganic) range from
less than 1 ppm to greater than 75 percent.
Appendix B lists major mercury compounds, their physical and chemical
properties, and, in some cases, industrial uses. Based on the data in
Appendix B and data from the Generator Survey, the Agency believes that
D009 wastes represent a universe of different wastes.
2.3 Determination of Waste Treatabilitv Groups
i
EPA has evaluated the characteristics of the K-, P-, D-, and U-code
mercury wastes and the processes generating these wastes to determine
whether any wastes or groups of wastes can be treated to similar levels
using the same technology. If so, these wastes could be classified as a
single treatability group.
In some cases, wastes classified under the same waste code may not be
treatable to the same concentrations using the same technology or may
require different treatment technologies (e.g., wastewater and
nonwastewater forms of the same waste). Also, D009 wastes may have the
same waste code but they are generated by different processes or by
different industries. As a result, D009 wastes can have different waste
characteristics, such that the wastes may not be treatable to similar
concentrations using the same technology. In these instances, the Agency
may subdivide waste codes into several treatability groups.
2-19
2862g
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Alternatively, facilities unable to meet the promulgated standards can
petition the Administrator for a variance from the treatment standard.
EPA expects the chemical forms of some D-code wastes, in particular, to
be different and to clearly require different treatments or combinations
of treatments. For example, inorganic and organometallic compounds
contain the same metal but may require different types of treatment in
order to comply with the treatment standards.
The treatability groups defined by the Agency for the mercury wastes
K106, P065, P092, U151, and D009 are discussed in the following
subsections. Although D009 wastes can vary, they are not expected to
constitute more than one treatability group based on the available
information for the physical and chemical properties of major mercury
compounds and the operating parameters of BOAT technologies (e.g.,
temperature, pH, and solubility). Also, this determination is based on
the available treatment information for D009 wastes showing that these
D009 wastes have treatability characteristics similar to those of one of
the mercury wastes identified by EPA as a K, U, or P waste groups. Some
subcategories of D009 wastes have thus been combined with the similar K-,
U-, or P-code waste or wastes into treatability groups.
2.3.1 Mercury Nonwastewaters
Based on the available waste characterization data, the chemical and
physical behavior of mercury compounds upon treatment, and the
performance of treatment technologies identified as BOAT, EPA has
determined that all mercury nonwastewaters fall into two general
treatability groups: (1) the high-mercury treatability subgroup and
(2) the low-mercury treatability subgroup. EPA has determined that an
exception to these general two subcategories are mercury wastes also
showing radioactive characteristics.
EPA lacks data to define the nature and characteristics of all wastes
in these groups. However, the available data indicate that most mercury
2-20
2862g
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nonwastewaters currently being retorted/roasted contain inorganic
mercury. These same data indicate that nonwastewater wastes derived from
the treatment of organomercury wastes can also be retorted. Other
mercury wastes, however, such as mercury fulminate (P065), may require
pretreatment, such as incineration or chemical treatment, to convert the
wastes to a form more amenable to recovery/recycling.
In the absence of other characterization data that can further define
those nonwastewaters amenable to retorting/roasting, EPA is relying on
characterization data from untreated mercury wastes being retorted/
roasted to establish 260 mg/kg as a cutoff level to define the high- and
low-mercury treatability groups. Derivation of this cutoff level is
discussed in Section 7.2. Inorganic and organic mercury nonwastewater
members of these two treatability groups are discussed below.
(1) Inorganic mercury nonwastewaters. EPA has identified certain
wastes as inorganic mercury nonwastewaters. These wastes are expected to
contain mercury in the metallic form or as inorganic mercury compounds
and are not expected to contain significant concentrations of organic
compounds. These wastes include waste codes K106, U151, and many D009
wastes. Mercury fulminate (P065) dissociates in water to mercury ions
and cyanate ions and therefore is chemically more similar to inorganic
mercury compounds than to organomercury compounds. P065 and other
reactive mercury wastes will, however, be discussed with the organic
mercury wastes because they can be treated by similar technologies such
as incineration.
Inorganic mercury nonwastewaters (K106, U151, and D009 wastes) are
amenable to mercury recovery technologies because the mercury is present
in the elemental form or as inorganic mercury compounds. Domestically,
inorganic mercury nonwastewaters with untreated mercury concentrations
starting at 255 mg/kg have been demonstrated to be retorted. EPA had
data indicating that in foreign countries wastes with mercury levels as
2-21
2862g
-------
low as 10 mg/kg have been demonstrated to be retorted. In addition, data
from thermal processing of cinnabar ore indicate that mercury sulfide
compounds can be retorted/roasted for mercury recovery.
Based on the available information and for the purpose of this rule,
EPA has determined that nonwastewater forms of mercury wastes having
concentrations of mercury above 260 mg/kg can be retorted/roasting.
Hence, EPA has divided these wastes into two treatability groups: the
high-mercury treatability group and the low-mercury treatability group.
This reflects the applicability of mercury recovery technologies to only
mercury nonwastewaters containing recoverable concentrations of mercury.
K106 wastes, as generated, contain from 0.5 percent to 16 percent
mercury, normally (except for one known generator) in the form of
mercuric sulfide (see Table 2-4). Sulfide-containing residuals from
wastewater treatment not listed as K106 may also be classified as D009
wastes or (by the "derived-from" rule) as U151, P065, or P092.
Mercuric sulfide has the highest decomposition temperature of any of
the common mercury compounds (Weast 1977). Because decomposition is the
first step in the volatilization of mercury compounds in mercury
recovery, these wastes are expected to be the most difficult from which
to recover mercury.
Other inorganic wastes contain mercury either in the elemental form
or as nonsulfide compounds. These wastes are expected to be more easily
treatable by mercury recovery technologies than are the mercuric sulfide
wastes.
K106 nonwastewaters are generated at one mercury cell chloralkali
facility by treatment of wastewaters using hydrazine as a reducing agent
to precipitate mercury as mercuric hydroxide and metallic mercury. The
sludges generated from filtration of this wastewater would be expected to
contain mercury and mercury oxide or hydroxide compounds.
2-22
2862g
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U151 nonwastewaters and some D009 nonwastewaters also contain
elemental mercury or inorganic mercury compounds as the primary
constituent. The Agency's data on the composition of U151 wastes
(summarized in Section 2.2.4) indicate that the majority of these wastes,
when not mixed with other wastes, are composed of greater than 50 percent
mercury. D009 wastes containing mercury or nonsulfide inorganic mercury
compounds as the major constituent would also be expected to be treatable
to similar levels as U151 wastes and nonsulfide K106 wastes using the
same technologies.
(2) Organic mercury nonwastewaters. These wastes comprise P065
nonwastewaters and P092 nonwastewaters, as well as some D009
nonwastewaters. The Agency expects some D009 nonwastewaters to contain
organomercury compounds or mercury in an organic waste matrix. These
wastes may be generated from paint formulation, from the manufacture of
organomercury Pharmaceuticals, and from the use of homogeneous mercury
catalysts in the production of organic chemicals. Because of the
presence of organomercury compounds (such as phenylmercuric acetate) or
organic compounds in the waste, these wastes may require pretreatment
(such as incineration) prior to being treated by the same technologies as
D009 nonwastewaters containing only inorganic mercury compounds.
P065 wastes and D009 wastes containing explosive mercury compounds
may require specially-designed incinerators for treatment. EPA has no
data on the composition of P065 wastes, but expects mercury fulminate to
be the major constituent. Mercury fulminate and mercury azide, both
extremely explosive compounds used as explosive initiators, may also be
the major constituent of some D009 wastes. The Agency expects that both
nonwastewater and wastewater forms of these wastes will be treatable to
similar levels as other inorganic nonwastewaters and wastewaters after
treatment of these wastes to remove the reactivity hazard.
2-23
2862g
-------
2.3.2 Radioactive Wastes Containing Mercury
Information provided to EPA by the United States Department of Energy
(DOE) indicates the generation of two mixed radioactive/hazardous wastes
that contain mercury. Treatment technologies applicable to other
mercury-containing nonwastewaters may not be applicable to treatment of
these wastes. The Agency, therefore, has established two separate
treatability groups for radioactive wastes containing mercury, which are
discussed below.
In the nuclear industry, elemental mercury found in vacuum pumps,
manometers, and other instruments may be contaminated with radioactive
tritium (a radioisotype of hydrogen). These wastes are often identified
as D009 or U151. The Agency has no data or information indicating that
recovery processes applicable to treatment of other inorganic mercury
nonwastewaters would be able to separate the mercury from the radioactive
material and recover reusable mercury. These wastes thus represent a
separate treatability group from other inorganic high-mercury
nonwastewaters.
The DOE also indicated the generation of a hydraulic oil contaminated
with mercury and tritium. This waste is expected to be similar to the
organic mercury nonwastewaters identified in Section 2.3.1 above in that
the organic components of the waste would have to be treated before the
mercury could be treated effectively. Treatment of this waste may be
different from treatment of the other organic nonwastewaters, however,
because recovery technologies may not be applicable for treatment of the
nonwastewater residuals generated from incineration since reusable (i.e.,
nonradioactive) mercury may not be recoverable from these residuals.
Radioactive hydraulic oils containing mercury thus represent a separate
treatability group from other organic mercury nonwastewaters.
2-24
2862g
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2.3.3 Wastewaters
EPA has determined that K106, U151, P065, and P092 wastewaters
represent a single treatability group. K106 wastewaters are generated
from^treatment of K106 wastes (e.g., as scrubber waters from thermal
treatment methods). EPA has no data on the composition of K106, U151, or
D009 wastewaters. However, the Agency expects K106 wastewaters to
contain only the major constituents, which are mercury and non-BDAT list
inorganics, reported for K106 wastes as generated (as shown in
Table 2-4). EPA expects K106 and U151 wastewaters to contain suspended
or dissolved metallic mercury or soluble inorganic mercury compounds
(e.g., mercuric chloride). EPA has no data on P092 wastewaters, but
expects these wastes to contain phenylmercuric acetate, a soluble
organomercury compound, as a major constituent.
D009 wastewaters containing suspended or dissolved metallic mercury
or soluble inorganic mercury compounds are expected to be amenable to
treatment by the same technologies as are applicable for treatment of
K106 wastewaters. As discussed in Section 2.1.3, EPA also expects D009
wastes generated from the paint formulation industry to contain
phenylmercury compounds in an organic or inorganic waste matrix. Other
D009 wastes, as generated, may be mixed with solvent constituents (USEPA
1986b) . These wastewaters may require other treatment trains (e.g.,
chemical oxidation with reagents such as hypochlorite or hydrogen
peroxide) in order to treat organics that may interfere with the
treatment of mercury. However, EPA currently lacks information to
indicate that these wastes cannot be treated to levels similar to those
achieved for inorganic mercury wastewaters.
2-25
2862g
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3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
In the previous section, discussions of the industries and processes
generating mercury-containing wastes and major constituent analyses of
these wastes were presented. Treatability groups were identified for the
mercury-containing wastes. This section describes the applicable and
demonstrated treatment technologies for each mercury treatability
subgroup. The technologies that are considered applicable to the
treatment of mercury-containing wastes are technologies that treat BDAT
list metals by reducing their concentration and/or their leachability in
the waste and technologies that treat the organic compounds or
organomercury compounds found in these wastes (so that the mercury left
behind can subsequently be treated). Detailed discussions of these
treatment technologies can be found in EPA's Treatment Technology
Background Document (USEPA 1989b).
3.1 Applicable Treatment Technologies
Based on the waste characteristics discussed in the previous section,
the technologies applicable for treatment of mercury-containing wastes
are those that reduce the concentration of BDAT list metals and/or reduce
the leachability of these metals leaving behind a treated residual
acceptable for land disposal. Because organic mercury wastes (P092
wastes and some forms of D009 wastes) may contain organic mercury com-
pounds or mercury compounds in an organic waste matrix, treatment tech-
nologies that are applicable to these wastes must also be able to free
the mercury from its organic bond so that subsequent mercury treatment is
effective. P065 and some D009 wastes contain carbon-mercury compounds
that show reactive characteristics, and these compounds must be treated
for those reactive characteristics prior to treatment to recover mercury.
3-1
2863g
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3.1.1 Applicable Technologies for Nonwastewaters
The Agency has identified thermal mercury recovery processes, the
acid leaching process, and stabilization as applicable for treatment of
nonwastewaters containing metallic mercury and/or inorganic mercury
compounds. Incineration and chemical oxidation have been identified as
applicable for treatment of nonwastewaters containing organomercury
compounds or mercury in an organic waste matrix. Aqueous chemical
deactivation and incineration in units specially designed for treatment
of explosive wastes have been identified as applicable treatment
technologies for treatment of reactive mercury-containing nonwastewaters.
Absorption technologies have been identified as applicable for treatment
of spilled metallic mercury wastes.
(1) Thermal mercury recovery processes. Thermal mercury recovery
processes volatilize mercury from the waste at high temperatures and then
condense and collect it as the pure metal, reducing the mercury
concentration in the treatment residual compared to that in the untreated
waste. Thermal recovery processes for mercury include retorting,
roasting, distillation processes (vacuum distillation or batch steam
distillation), and thermal processes recovering mercury from concentrated
mercury ores.
Retorting and roasting processes can be operated as batch processes
in a closed vessel or continuously in a furnace. In retorting processes,
waste is heated and mercury vaporizes and is collected in a condenser.
The vessel is usually kept either at a slightly negative pressure or
under a strong vacuum. Air is not introduced from outside the vessel.
Roasting processes are usually operated continuously, but may be operated
in batch. In roasting, air is supplied to the system as a source of
oxygen to enable decomposition of some mercury compounds. Retorting and
high-temperature metals recovery technologies are discussed further in
the Treatment Technology Background Document (USEPA 1989b).
3-2
2863g
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Distillation technologies are applicable to treatment of wastes
containing high concentrations of metallic mercury (such as U151). The
residuals from distillation technologies are a high-purity mercury as the
"overhead" product and the remaining solid residual as the "bottoms."
Distillation processes are also discussed in the Treatment Technology
Background Document (USEPA 1989b).
The thermal process used to recover mercury from concentrated mercury
ores is very similar to continuous retorting. These two thermal
processes used to recover mercury take place in a multiple hearth furnace
followed by condensation of volatilized mercury. All four thermal
mercury recovery processes discussed above may generate a wastewater from
air pollution control equipment that may contain mercury.
(2) Acid leaching process. Acid leaching solubilizes low
concentrations of mercury in wastes, reducing the concentration of
mercury in the nonwastewater treatment residual. The acid leaching
process used for treatment of K071 wastes involves a chemical oxidation
step followed by a step combining sludge dewatering and acid washing.
This process generates an acid leachate (wastewater) that contains the
mercury in soluble ionic form and requires treatment by chemical
precipitation. Acid leaching is described in the Treatment Technology
Background Document (USEPA 1989b).
(3) Stabilization. Stabilization is applicable for treatment of
nonwastewaters containing BOAT list metals in an inorganic waste matrix.
Stabilization treatment involves mixing the waste with a binding agent
that is designed to reduce the leachability of metals from the waste.
Common stabilization technologies are discussed in detail in the
Treatment Technology Background Document (USEPA 1989b).
3-3
2863g
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(4) Incineration. Incineration is applicable to treatment of
wastes containing organic and organometallic constituents. Treatment
using incineration technologies will destroy the organic constituents of
the waste. As a consequence of destruction of the organics, incineration
will break the organic-metal bond in the organometallic waste
constituents. The metallic part of the organometallic constituents in
the waste, as well as any metals present in a mixed metal/organic waste,
will remain in the residual (ash) generated, will be removed from the
gases exiting the incinerator by the air pollution control equipment, or
will remain in the gases exiting the incineration system. Incineration
technologies are described in the Treatment Technology Background
Document (USEPA 1989b).
(5) Chemical oxidation of organomercurv compounds. Chemical
oxidation is applicable to the treatment of wastes containing
organomercury constituents (such as phenylmercuric acetate, P092).
Chemical oxidation treatment of organomercury compounds involves addition
of a chemical oxidizing agent such as chlorine, hypochlorite,
permanganate, or ozone in an aqueous reaction medium. Chemical oxidation
results in the breaking of the organic-mercury chemical bond, thereby
generating a residual from which the organic contaminant can either be
destroyed (by further oxidation or incineration) or recovered (by
distillation). Chemical oxidation is discussed in the Treatment
Technology Background Document (USEPA 1989b). The inorganic mercury
wastewaters resulting from chemical oxidation treatment can be treated by
one of the technologies identified in Section 3.1.2 as applicable for
wastewaters containing inorganic mercury compounds.
(6) Aqueous chemical deactivation. Aqueous chemical deactivation
is applicable for treatment of wastes containing reactive mercury
constituents (such as mercury fulminate, P065). Aqueous chemical
deactivation involves careful dissolution of explosive solids in water,
3-4
2863g
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combined with oxidation treatment of the dissolved waste. In the case of
mercury fulminate (mercuric cyanate), the dissolved cyanate ions can be
chemically oxidized completely to carbon dioxide and nitrogen using
strong aqueous oxidizing agents such as sodium hypochlorite. The
chemical reaction of mercury fulminate with sodium thiosulfate
(Na2S2Oo), recommended by the Army as the proper chemical
deactivating agent (U.S. Army 1984), forms thiocyanate as follows:
Hg(OCN)2 + 2Na2S203 -» HgS04 + Na2S04 + ZNaSCN
(7) Absorption of elemental mercury. Several methods have been
developed to handle spills of liquid metallic mercury. These methods
involve absorption of mercury with several agents. Calcium polysulfide
and flowers of sulfur are the most common mercury absorbents used, and
elemental zinc powder is also used.
Because of the high vapor pressure associated with elemental mercury
in the liquid form (compared to other metals), the predominant safety
concern with elemental mercury wastes is air emissions. In absorption of
liquid mercury with zinc dust, elemental zinc powder is applied to areas
that have been contaminated with mercury. The visible droplets of liquid
mercury are physically collected in a separate step before application of
the zinc. The zinc is dampened with dilute sulfuric acid (5 to 10
percent) until a paste is formed. This paste is then collected for
disposal. The mercury forms an amalgam with the zinc, providing a
significant reduction in air emissions of mercury (Easton 1988). EPA
prefers this procedure over the conventional spill cleanup procedures
involving addition of calcium polysulfide or flowers of sulfur because
use of zinc results in lower air emissions of mercury.
3-5
2863s
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3.1.2 Applicable Technologies for Vastevaters
(1) Chemical precipitation and chemical reduction. EPA has
identified chemical precipitation and chemical reduction, both followed
by filtration, as applicable to treatment of mercury-containing
wastewaters with high concentrations of inorganic mercury compounds.
Chemical precipitation followed by filtration removes BOAT list metals
and concentrates them in the wastewater treatment sludge. Chemical
reduction (with reagents such as sodium borohydride) reduces mercury to
the metallic state. The reduction step is then followed by filtration to
remove mercury and other solids.
The applicability of chemical precipitation and chemical reduction
technologies depends to some extent on the form of mercury in the waste
(e.g., dissolved ionic, pure metal, and insoluble ionic). Mercury in the
dissolved ionic form (soluble mercuric compounds, for example) may be
reduced to the pure metal by the borohydride reduction process, while
this process may not be effective in treatment of the insoluble mercury
compounds. The borohydride process cannot remove the small amount of
metallic mercury that is soluble in water. Chemical oxidation treatment
may be required to oxidize metallic mercury to soluble ionic mercury
prior to chemical precipitation treatment. Chemical precipitation,
chemical reduction, and chemical oxidation technologies are discussed in
the Treatment Technology Background Document (USEPA 1989b). The solids
produced as a residual from chemical reduction processes are, in general,
easier to treat by high-temperature metals recovery methods than are the
solids produced in chemical precipitation treatment because they contain
mercury in its elemental form rather than as mercuric salts.
(2) Chemical oxidation of oreanomercurv constituents. EPA has
identified chemical oxidation followed by chemical precipitation and
filtration as an applicable technology for wastewaters containing
3-6
2863g
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organomercury constituents. Chemical oxidation breaks the bonds between
the mercury and the organic components of these constituents, as
discussed in Section 3.1.1(5). Chemical precipitation then treats the
mercury in the inorganic form.
(3) Carbon adsorption and ion exchanee. Two other technologies,
carbon adsorption and ion exchange, are also applicable to treatment of
wastewaters containing relatively low concentrations of dissolved
+2
mercury. The mercury must be in the soluble mercuric (Hg ) form in
order to be removed by these technologies (Rosenzweig 1975, lammartino
1975). Thus, these technologies may require pretreatment by chemical
oxidation to solubilize any insoluble inorganic mercury. Carbon
adsorption will also remove mercury from wastes containing dissolved
organomercury compounds.
Carbon adsorption and ion exchange produce both a wastewater residual
(from regeneration of the ion exchange resin or activated carbon bed) and
a nonwastewater residual (the spent carbon or ion exchange resin, when
these are exhausted and must be discarded). The waste regenerant
solutions (usually acid solutions) are more concentrated than the
original waste treated and must usually be treated for mercury removal by
chemical precipitation followed by filtration if these regenerant
solutions are not recyclable to the process originally generating the
waste. Spent carbon can be incinerated (if mercury emissions are
controlled) or processed in a retort to recover residual mercury. The
spent resins may also be processed by retorting to recover residual
mercury. Carbon adsorption and ion exchange technologies are discussed
in the Treatment Technology Background Document (USEPA 1989b).
3.2 Demonstrated Treatment Technologies
Section 3.1 described applicable technologies for treatment of
mercury wastes. This section identifies, for nonwastewaters and
3-7
2863g
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wastewaters, those applicable technologies that are demonstrated in terms
of the waste treatability groups that were discussed in Section 2.3. To
be demonstrated, a technology must be in full-scale use to treat either
the waste in question or a similar material.
3.2.1 Demonstrated Technologies for Nonwastewaters
Retorting, roasting, batch distillation technologies, and thermal
treatment of mercury ores are all demonstrated for treatment of
nonwastewaters containing mercury as the metal or as inorganic mercury
compounds. Another demonstrated technology to treat mercury wastes
(soluble inorganic mercury) is acid leaching. During the comment period
for the proposed rule, EPA received numerous comments disputing EPA's
determination that retorting/roasting has been demonstrated for
mercury-containing nonwastewaters. These comments are addressed in
Section 5.1.1.
Incineration has been identified as demonstrated for treatment of
nonwastewaters containing organomercury constituents or containing
inorganic mercury in an organic waste matrix. EPA received comments
during the comment period for the proposed rule indicating that direct
retorting/roasting of organomercury wastes is demonstrated and
practical. Also, EPA has information for an oxidation-retorting patented
process demonstrated for organomercury wastes. EPA has information that
this process is also demonstrated for inorganic mercury wastes. This
oxidation-retorting process is deemed as retorting by EPA for the purpose
of this rule. Incineration in specially-designed units has been
identified as demonstrated for explosive mercury nonwastewaters.
Retorting was used in the past to treat K106 at two mercury cell
chloralkali facilities. Also, retorting was used to treat a mixture of
K071 and K106 at another facility. EPA is not aware of any facilities
3-8
2863g
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currently retorting K106 sulfide wastes. However, a thermal treatment
process similar to retorting is presently being used at one facility for
recovery of mercury from ores consisting primarily of mercuric sulfide
(cinnabar) (K106 also ordinarily contains primarily mercury sulfide).
These ores are concentrated to approximately 70 to 75 percent mercury
prior to retorting (from 3 percent in the unprocessed ores). As shown in
Table 2-4, the concentration of mercury in nonwastewater K106 generated
by sulfide treatment averages 4.4 percent, and the concentration of
mercury in K106 generated by hydrazine treatment is 0.5 percent. The
processed mercury ores are much more concentrated in mercury (as mercury
sulfide) than either form of K106. Hence, the Agency believes that the
mercury ores are much more difficult to treat than K106. As a
consequence, the Agency considers retorting to be demonstrated for K106
and other sulfide-containing nonwastewaters.
Retorting is also demonstrated at two additional facilities for
treatment of nonsulfide-containing mercury nonwastewaters. U151 wastes
and inorganic D009 wastes such as mercury lamps, debris, contaminated
equipment, and mercury cell batteries are routinely treated by retorting,
vacuum or scrap metal distillation, and a thermal proprietary process.
Incineration is demonstrated for many RCRA-listed hazardous wastes
that contain BDAT list metals (such as K048-K052 and K087). EPA believes
incineration is currently used for treatment of organomercury wastes such
as spent mercury catalysts from organic chemicals production, paint
sludges, or organomercury lab packs. Incineration in specially-designed
units has been identified as a demonstrated technology for many D001
reactive wastes (USEPA 1989e), including some wastes that contain metals
as well as organics. The U.S. Army recommends this technology for
treatment of mercury fulminate (P065) wastes (U.S. Army 1984).
3-9
2863g
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Application of elemental zinc powder to form a zinc-mercury amalgam
is a common demonstrated method of cleanup of spilled mercury (Easton
1988). This technology is expected to provide some treatment for
radioactive metallic mercury wastes, for which mercury recovery
technologies may not be applicable.
Acid leaching is demonstrated at chloralkali facilities generating
K071 wastes. K071 wastes contain soluble mercuric chloride, insoluble
mercuric oxide, and elemental mercury (USEPA 1988b). This technology
requires an additional step of oxidation to convert insoluble forms of
mercury to the mercuric (+2) form, which is soluble. The soluble
mercuric form can then be precipitated as sulfide salt. Several
commenters submitted comments supporting the demonstrability of this
technology but noting that it may not be suitable for "elemental mercury
and mercury oxides." However, these commenters failed to submit data
supporting these claims of limitations in the applicability of acid
leaching technologies. Based on the K071 data, EPA believes this
technology is demonstrated for most mercury compounds listed in
Appendix B that show solubility ranges similar to those of the mercury
compounds identified in K071 wastes.
Stabilization was identified as potentially applicable for treatment
of K106 nonwastewaters and possibly certain D009 nonwastewaters.
Stabilization typically binds BDAT list metals into a solid in a form
that is more resistant to leaching than the metals in the untreated
waste. EPA's testing of cement, kiln dust, and lime/fly ash stabilization
for treatment of K106 nonwastewaters generated by sulfide precipitation
indicates that the technology did not provide effective treatment. EPA
believes the ineffectiveness of stabilization treatment of K106 in this
EPA test may have resulted from the mercury sulfide behavior in alkaline
media. Similarly, industry submitted data on stabilization of "D009
soil/debris" and unspecified D009 or K071 waste, but these data show
untreated and treated waste TCLP concentrations below the toxic
characteristic level (HWTC 1989a,b; Chemfix 1989) for D009 wastes.
3-10
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Based on the available data, EPA has concluded that stabilization
with alkaline materials may not be demonstrated for K106 wastes
containing high concentrations of mercury sulfide. The stabilization
data collected by EPA are summarized in Section 4.1. It is possible that
stabilization may be applicable for treatment of other mercury containing
wastes if mercury is present in a more leachable form (e.g., a nonsulfide
form) or is present at low concentrations in the untreated waste (based
on the data received during the comment period for this rule; see
Table 4-8). Other stabilizing agents, such as proprietary asphalt or
silicate agents, may also be applicable, but data to enable such a
determination have not been provided to EPA.
3.2.2 Demonstrated Technologies for Wastewaters
Chemical precipitation followed by filtration has been demonstrated
for treatment of K071 wastewaters. EPA does not have characterization
data on K106 wastewaters generated from retorting of K106. However, EPA
does have data on wastewaters generated from air pollution control
devices from the thermal processing of mercuric sulfide ores to recover
metallic mercury. The Agency believes that these wastewaters (K106
wastewaters and wastewaters produced from mercuric sulfide ore
processing) are similar to the K071 and other mercury-contaminated
wastewaters currently treated by chemical precipitation (see Table 4-7)
because they are expected to contain mercury as the major BDAT list
constituent end are not expected to contain concentrations of organic
compounds that would affect treatment by chemical precipitation. The
mercury compounds expected to be found in wastewaters from processing
K106 wastes should be easier to treat than those present in K071
wastewaters. K071 wastewater contains soluble mercury, mercury compounds
such as mercury chloride (produced from acid leaching of K071
nonwastewaters). K106 (and also mercury sulfide ore processing)
wastewaters are, in large part, scrubber waters in which mercury is
3-11
2863g
-------
expected to be present in metallic or oxide form, since it is metallic
mercury that vaporizes from the retorter or roaster. Metallic mercury
and oxides of mercury are essentially insoluble and may only require
treatment by coagulation and settling, while the mercury chlorides in
K071 require chemical precipitation (e.g., with sulfide) in addition to
coagulation and settling. The concentration of mercury in the
wastewaters for which the Agency has treatment data ranges from 9.25 to
77.2 mg/1. The ore roasting air pollution control wastewaters contained
a maximum mercury concentration of 8.52 mg/1 (see Table 4-1). EPA would
not expect the K106 wastewaters generated from retorting to be more
difficult to treat than the waste tested by the Agency because they are
expected to have concentrations of mercury similar to that of the ore
roasting air pollution control wastewaters generated in EPA testing of
mercuric sulfide ore roasting. Chemical precipitation followed by
filtration of mercury-containing wastewaters is demonstrated and
practiced at 19 or more facilities.
Ion exchange is demonstrated at many facilities in Europe for
treatment of wastewaters generated from the mercury cell chloralkali
process. Activated carbon adsorption is also used at several facilities
for treatment of inorganic/organo mercury-containing wastewaters
(Rosenzweig 1975).
Therefore, the Agency believes that chemical precipitation, ion
exchange, and carbon adsorption are all applicable and demonstrated for
treatment of wastewaters generated from thermal treatment of K106
wastewaters and for treatment of wastewaters generated from the
management of other mercury-containing treatment sludge wastes.
Chemical oxidation technologies are also demonstrated for treatment
of wastewaters containing oxidizable inorganic constituents (such as
cyanide or cyanate) (USEPA 1989f).
3-12
2863g
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As discussed in Section 3.2.1, incineration in specially-designed
units is demonstrated for explosive mercury nonwastewaters. This
technology, as well as aqueous chemical deactivation by chemical
oxidation, is also recommended by the Army for treatment of mercury
fulminate wastewaters. Chemical oxidation is also demonstrated for many
wastewaters containing organics or oxidizable inorganics (such as
cyanate).
3-13
28636
-------
4. PERFORMANCE DATA
4.1 Performance Data for Nonwastewaters
For treatment of inorganic mercury-containing nonwastewaters, EPA has
treatment performance data as described below. EPA collected five sets
of treatment data from a thermal mercury recovery system that processes
mercuric sulfide ores for mercury recovery. These data, presented in
Table 4-1 (at the end of this section), show total composition, TCLP, and
EP leachate data for both the untreated mercury ores and the treated
nonwastewater furnace residue and also include data for the wastewaters
generated from the air pollution control devices (APCDs). Table 4-2
presents total composition, TCLP, and EP leachate data for two samples of
dust collected from the dust cyclone component of the APCD. Also
presented are design and operating data associated with each sample set.
Plant B submitted four sets of performance data for retorting
treatment of K106 hydrazine sludge, presented in Table 4-3. These data
include total and EP leachate concentration of mercury in the untreated
waste and data for mercury and the other EP metals in the treated
nonwastewater residual, as well as design and operating data associated
with each sample set. Table 4-4 also presents performance data for
retorting of K106 hydrazine sludge. Total mercury concentration in the
untreated waste and total mercury and EP leachate concentrations for the
treated waste are provided for 35 sets of data.
Table 4-5 presents two sets of performance data on retorting
treatment of a combined K071/K106 waste. These data show total mercury
concentration for each test in the untreated waste and a range of total
mercury concentrations for the treated nonwastewater residual, as well as
design and operating data for each sample set. No leachate concentration
data were generated for untreated or treated wastes.
4-1
2664g
-------
Plant C submitted seven sets of performance data for retorting of a
K106 sludge generated by sodium borohydride reduction and filtration.
These data, presented in Table 4-6, show total mercury concentration of
the untreated waste and total and EP leachate mercury concentrations for
the treated nonwastewater residual. No design or operating data were
included.
Oxychem (1989, 1990) provided total mercury concentration data for
residuals from retorting of D009 mercury cell room trench sludge. Twelve
data points for retorted D009 wastes were submitted describing mercury
concentrations ranging from 32 to 2,042 rag/kg. No data were generated on
the untreated wastes prior to retorting, nor was any EP toxicity or TCLP
testing performed on the treated residuals.
Table 4-7 presents data collected by EPA on stabilization of K106
wastes. These data show the total and TCLP BDAT list metal
concentrations for the untreated waste and the TCLP concentration for the
treated waste. Three binding agents (lime/fly ash, kiln dust, and
cement) were tested. The table presents the results of the test for kiln
dust, which was the most successful of the three binding agents in terms
of reduction of the TCLP leachate concentration for mercury. Note the
results for sample set No. 2 show a significant increase in mercury TCLP
leachate concentration in the treated waste compared to that in the
untreated waste.
Table 4-8 presents industry-submitted data on stabilization of "D009
contaminated soil and debris from the natural gas pipeline industry"
(HWTC 1989a,b). The wastes were stabilized using undisclosed,
proprietary reagents. Data were submitted for total mercury content of
the untreated wastes and TCLP of the treated waste for four sample sets.
Untreated waste TCLP concentrations were reported for only two of the
sample sets. Both the untreated and treated TCLP results are less than
4-2
286<.g
-------
the toxic characteristic level for mercury. One of the treated waste
TCLP values was greater than the untreated value. Because of the small
size of this data set and the low untreated waste concentrations
involved, EPA does not believe a performance evaluation would be
meaningful. Treatment data submitted by Chemfix for unspecified D009
wastes and possibly a K071 waste were too incomplete (no QA/QC data or
design and operating data were provided) to enable any performance
evaluation to be made (Chemfix 1989). EPA requested additional
information from Chemfix, but this commercial vendor has not yet provided
the requested information.
Data were presented in the BOAT background document for K071 (USEPA
1988b) on acid leaching treatment of K071 wastes. These data included
both EPA-collected data and data submitted by industry.
4.2 Performance Data for Wastewaters
The Agency collected three data sets of untreated and treated data
for treatment of K071 wastewater in a sulfide precipitation and
filtration treatment system. The treatment performance data for K071
wastewaters are presented in Table 4-9.
EPA does not have analytical data on wastewaters as generated from
retorting operations. EPA believes that these wastewaters would be
similar in chemical and physical characteristics to wastewaters generated
in treatment of K071 waste by acid leaching and other mercury-containing
wastewaters.
The Agency does have data characterizing the wastewater generated
from air pollution control at the facility at which mercuric sulfide ores
were processed. These wastewaters contained up to 8.4 mg/1 mercury and
are similar in composition to K071 wastewaters.
4-3
2864g
-------
2872g
Table 4-1 Ore Roasting Performance Data from Thermal Recovery of
Mercuric Sulfide Ores Collected by EPA at Plant A
Sample Set No. 1
Untreated waste
Constituent
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total
(rag/kg)
330
290
13
0.15
3.4
2.8
8.2
3.1
625,000
<1.0
3.6
2.8
6.2
5.4
50
Note: Design and operating
Parameter
TCLP
(mg/1)
0.82
0.41
0.69
<0.001
<0.005
<0.003
0.012
<0.05
0.26
<0.01
<0.005
<0.004
0.03
<0.003
0.33
parameters
EP leachate
(mg/1)
1
0.33
0.19
-
0.007
0.009
-
<0.028
0.10
-
<0.005
<0.004
-
-
are as follows:
Design value
Treated nonwastewater
Total
(mg/kg)
,170
960
77
0.39
5.0
5.2
23
5.8
45
2.0
<0.5
7.6
<1.0
27
94
TCLP EP leachate
(mg/1) (mg/1)
0.47
7.3 4.54
0.21 0.14
0.0013
0.051 0.037
<0.003 <0.003
<0.003
<0.005 <0.028
<0.0002 <0.0002
<0.01
<0.05 <0.05
<0.004 <0.004
<0.01
0.012
0.17
Air pollution
control wastewater
Total (mg/1)
3.23
0.023
0.007
<0.002
<0.004
<0.007
<0.003
0.011
3.25
<0.013
<0.005
<0.003
0.013
<0.003
0.026
Operating value
Temperature of
#2 furnace hearth fF)
1350-1450
1500-1530
Temperature of
#4 furnace hearth ("F)
1450-1550
1580
Ore concentrate
feed rate (Ib/hr)
1000-1300
1370
- = Not analyzed
Source: USEPA 1989g.
4-4
-------
2872g
Table 4-1 (continued)
Sample Set No. 2
Untreated waste
Constituent
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total
(mg/kg)
360
280
12
0.13
2.7
3.1
8.4
3.2
738,000
<1.0
2.8
2.6
5.6
5.1
49
Note: Design and operating
Parameter
TCLP EP
(mg/1)
0.79
0.44
0.72
<0.001
0.006
0.004
0.013
<0.005
0.42
<0.01
<0.005
<0.004
0.03
<0.003
0.34
leachate
(mg/1)
2
0.33 1
0.14
-
<0.005
<0.003
-
<0.028
0.087
-
<0.005
<0.004
-
-
Treated nonwastewater
Total
(mg/kg)
,270
.290
66
0.43
7.4
5.8
26
10
42.4
3.5
<0.5
8.6
<1.0
24
120
TCLP EP leachate
(mg/1) (mg/1)
4.1
18.7 10.6
0.18 0.21
<0.001
0.15 0.095
<0.003 <0.003
<0.003
<0.005 <0.028
0.00047 <0.0002
<0.01
<0.05 <0.05
<0.004 <0.004
<0.01
0.021
0.26
Air pollution
control wastewater
Total (mg/1)
5.76
0.032
0.011
<0.002
<0.004
<0.007
<0.003
0.017
8.52
<0.013
<0.005
<0.003
0.029
<0.003
0.042
parameters are as follows:
Design
value
Operating value
Temperature of
#2 furnace hearth ('F)
Temperature of
#4 furnace hearth ('F)
Ore concentrate
feed rate (Ib/hr)
1350-1450
1450-1550
1000-1300
1440-1510
1540-1580
1370
- = Not analyzed
Source: USEPA 1989g.
4-5
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2872g
Table 4-1 (continued)
Sample Set No. 3
Untreated waste
Constituent
Antimony
Arsenic
Barium
Bery 1 1 i urn
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total
(mg/kg)
320
270
12
0.12
2.8
3.5
9.0
3.0
640,000
1.2
5.5
3.5
5.1
5.2
52
Note: Design and operating
Parameter
TCLP
(mg/1)
0.82
0.44
1.03
<0.001
0.008
0.006
0.014
<0.005
1.44
<0.01
<0.005
<0.004
0.031
<0.003
0.64
parameters
EP leachate
(mg/D
1
0.36 1
0.13
-
0.008
<0.003
-
<0.028
0.078
-
<0.005
<0.004
-
-
are as follows:
Design value
Treated nonwastewater
Total
(mg/kg)
.920
.220
70
0.45
7.1
5.6
32
7.0
36
3.6
<0.5
10
<1.0
30
140
TCLP
(mg/1)
0.94
12
0.18
<0.001
0.091
<0.003
<0.003
<0.005
<0.0002
<0.01
<0.05
<0.004
<0.01
<0.003
0.073
EP leachate
(mg/1)
.
1.1
0.13
-
0.014
<0.003
-
<0.028
<0.0002
-
<0.05
<0.004
-
-
Air pollution
control wastewater
Total (mg/1)
2.73
0.029
0.010
<0.002
<0.004
<0.007
<0.003
0.013
4.14
<0.013
<0.005
<0.003
0.027
<0.003
0.032
Operating value
Temperature of
#2 furnace hearth (*F)
Temperature of
#4 furnace hearth ('F)
Ore concentrate
feed rate (Ib/hr)
1350-1450
1450-1550
1000-1300
1480
1570
1370
- = Not analyzed
Source: USEPA 1989g.
4-6
-------
2872g
Table 4-1 (continued)
Sample Set No. 4
Untreated waste
Constituent
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total
(mg/kg)
350
300
14
0.16
3.3
3.7
9.0
3.3
473.000
1.0
1.2
3.2
5.1
5.8
51
Note: Design and operating
Parameter
TCLP EP
(mg/1)
0.84
0.42
0.77
<0.001
0.006
0.006
0.010
0.006
3.8
<0.01
<0.005
<0.004
0.037
<0.003
0.41
leachate
(mg/1)
2
0.36 1
0.14
-
<0.005
<0.003
-
<0.028
0.093
-
<0.005
«0.004
-
-
Treated nonwastewater
Total
(mg/kg)
,200
,590
66
0.43
9.6
6.4
28
15
23
4.6
<0.5
9.6
<1.0
27
160
TCLP EP leachate
(mg/1) (mg/1)
0.05
7.6 3.8
0.14 0.13
0.00014 -
0.061 0.03
<0.003 <0.003
<0.003
<0.005 <0.028
<0.0002 <0.0002
<0.01
<0.05 <0.05
<0.004 <0.004
<0.01
0.012
0.046
Air pollution
control wastewater
Total (mg/1)
5.13
0.041
0.010
<0.002
<0.004
<0.007
<0.003
0.019
7.26
<0.013
0.012
<0.003
0.041
<0.003
0.042
parameters are as follows:
Design
value
Operating value
Temperature of
#2 furnace hearth ('F)
Temperature of
#4 furnace hearth (*F)
Ore concentrate
feed rate (Ib/hr)
1350-1450
1450-1550
1000-1300
1490
1550-1560
1310
- = Not analyzed
Source: USEPA 1989g.
4-7
-------
2872g
Table 4-1 (continued)
Sample Set No. 5
Untreated waste
Constituent
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total
(mg/kg)
340
300
14
0.15
3.0
3.1
8.7
3.1
600,000
1.3
2.3
3.2
5.1
5.6
50
Note: Design and operating
Parameter
TCLP EP
(mg/D
0.90
0.41
0.76
<0.001
<0.005
0.005
0.013
0.007
1.7
<0.01
<0.005
<0.004
0.026
<0.003
0.38
leachate
(mg/D
2
0.36 1
0.14
-
<0.005
<0.003
-
<0.028
0.093
-
<0.005
<0.004
-
-
Treated nonwastewater
Total
(mg/kg)
.310
,250
71
0.37
7.6
5.9
30.8
7.4
11
3.1
<0.5
9.5
<1.0
29
140
TCLP EP leachate
(mg/1) (mg/1)
15
18 4.7
0.16 0.12
<0.001
0.13 0.042
<0.003
<0.003
<0.005 <0.028
0.006 <0.0002
<0.01
<0.025 <0.05
<0.004 <0.004
<0.01
0.004
0.24
Air pollution
control wastewater
Total (mg/1)
4.64
0.037
0.012
<0.002
<0.004
<0.007
<0.003
0.018
5.48
<0.013
<0.005
<0.003
0.043
<0.003
0.042
parameters are as follows:
Design
value
Operating value
Temperature of
12 furnace hearth CF)
Temperature of
#4 furnace hearth ('F)
Ore concentrate
feed rate (Ib/hr)
1350-1450
1450-1550
1000-1300
1490
1560-1580
1370
- = Not analyzed
Source: USEPA 1989g.
4-8
-------
\. rv
Table 4-2 APCDa Cyclone Dust Composition Data
from Thermal Recovery of Mercuric Sulfide Ores
Collected by EPA at Plant A
Constituent
BOAT List Metals
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cooper
Lead
Mercury
Nickel
Silver
Thallium
Vanadium
Zinc
BOAT List Inorganics
Sulfide
Other Parameters
Total organic carbon
Chloride
Sulfate
Total
(mg/kg)
17,200
2.100
35
1.1
12
4.8
18
23
2,400
4.5
6.6
18.4
12.6
161
ND
2,200
72.100
22,600
Untreated Waste
a
TCLP EP Leacnate
(mg/kg) (mg/kg)
29.3
32.3 0.27
0.28 0.25
ND
0.23 0.25
ND ND
ND
ND ND
ND ND
ND
ND ND
ND
ND
0.035
-
-
-
-
Concentration
b
Total
6,450
520
27
1.0
5.0
2.8
7.6
15
7,900
3.0
3.2
16.8
8.9
87.1
18.900
2.200
72.400
27.200
TCLP
(mg/kg)
24.6
0.28
0.20
ND
ND
ND
ND
ND
0.46
ND
ND
ND
ND
0.009
-
-
-
-
EP Leacnate
(mg/kg)
-
33.3
0.20
-
0.28
ND
-
ND
0.48
-
ND
-
-
-
-
-
-
-
Source: USEPA (1989g)
- = Not analyzed.
aAPCD •= Air pollution control device.
4-9
-------
2872g
Table 4-3 Treatment Performance Data for Retorting of K106 Hydrazine
Sludge Submitted by Plant B
Sample Set No. 1
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Silver
Untreated waste Treated
Total EP leachate Total
(mg/kg) (mg/1) (mg/kg)
2.5
48
3.0
38
56
4,300 4.8 100
39
<0.6
6.5
nonwastewater
EP leachate
(mg/1)
0.033
0.070
0.016
<0.005
<0.06
0.0017
0.090
<0.005
<0.007
Note: Design and operating parameters are as follows:
Parameter Design value Operating value
Retort temperature (°F)
1000
1000
- = Not analyzed
Source: Occidental Chemical Corporation 1987.
4-10
-------
2872g
Table 4-3 (continued)
Sample Set No. 2
Constituent
Arsenic
Barium
Cadin i urn
Chromium
Lead
Mercury
Nickel
Selenium
Silver
Untreated waste Treated
Total EP leachate Total
(mg/kg) (mg/1) (mg/kg)
2.7
44
2.8
35
99
5,500 5.3 90
35
<0.6
8.3
nonwastewater
EP leachate
(mg/1)
0.030
0.11
0.013
<0.005
<0.06
0.0024
0.11
«0.005
<0.007
Note: Design and operating parameters are as follows:
Parameter Design value Operating value
Retort temperature (°F)
1000
1000
- = Not analyzed
Source: Occidental Chemical Corporation 1987.
4-11
-------
2872g
Table 4-3 (continued)
Sample Set No. 3
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Silver
Untreated waste Treated
Total EP leachate Total
(mg/kg) (mg/1) (mg/kg)
1.1
45
3.9
68
85
2,500 5.6 47
42
<0.6
9.9
nonwastewater
EP leachate
(mg/D
0.021
0.13
0.012
<0.005
<0.06
0.0005
0.13
<0.005
<0.007
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Retort temperature (*F)
1000
1000
- = Not analyzed
Source: Occidental Chemical Corporation 1987.
4-12
-------
2872g
Table 4-3 (continued)
Sample Set No. 4
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Silver
Untreated waste Treated
Total EP leachate Total
(mg/kg) (mg/1) (mg/kg)
1.0
40
4.6
53
71
2,000 5.8 41
33
<0.6
9.5
nonwastewater
EP leachate
(mg/1)
0.021
0.14
0.015
<0.005
<0.06
<0.002
0.12
<0.005
<0.007
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Retort temperature (*F)
1000
1000
- = Not analyzed
Source: Occidental Chemical Corporation 1987.
4-13
-------
2872g
Table 4-4 Treatment Performance Data for Retorting of K106 Hydrazlne
Sludge Submitted by Plant B-2
Untreated waste
Constituent
(mercury only)
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Sample
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
Set
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
Total
(mg/kg)
9
7
8
8
32
27
7
17
7
7
5
5
5
4
3
4
3
4
9
5
6
6
7
8
6
5
5
9
5
2
3
5
6
4
6
.825
,375
,200
,750
,000
,000
,875
,325
,375
,125
,275
,275
,400
,600
.780
,390
,420
,280
,640
,800
,300
,933
,200
,000
,200
,100
.205
.100
,650
,600
,010
,480
,050
,500
,100
Treated nonwastewater
Total
(mg/kg)
167
637
470
375
124
205
40
104
60
45
60
110
27
41
87
41
10
544
362
1214
' 124
268
560
240
77
222
104
765
62
52
29
350
51
1,564
39
.5
.5
.0
.0
.0
.5
.0
.0
.5
.0
.0
.0
.3
.8
.5
.3
.5
.3
.8
.0
.5.
.0
.0
.0
.5
.5
.0
.0
.5
.5
.5
.0
.0
.0
.2
EP toxlcity
("9/1)
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0033
0330
0145
0011
0011
0075
0017
0047
0058
0031
0006
0006
0008
0001
0011
0080
0005
0115
0295
0525
0005
0029
0220
0036
0005
0018
0004
0139
0008
0004
0002
0071
0.0003
0.
0.
0502
0004
Note: Reported operating temperature of 800-950'F and typical burn time of 14
hours for a batch feed of 11.3 cubic feet.
Source: Oxychem 1989, 1990.
4-14
-------
2872g
Table 4-5 Treatment Performance Data for Retorting of Mixed K071/K106
Waste from Literature Source A
Constituent
Untreated waste
Total concentration
(ppm)
Treated waste
Total concentration
(ppm)
Sample Set No. 1
Mercury
345
0.5 - 0.8
Sample Set No. 2
Mercury
Sample Set No. 3
Mercury
255
290
1.6 - 3.1
1.7 - 2.6
Sample Set No. 4
Mercury
438
2 - 7.2
Sample Set No. 5
Mercury
370
1.6
Note: Design and operating parameters are as follows:
Parameter
Operating value
Design value SS#1 SS#2 SS#3 SS#4 SS#5
Waste feed rate (Ib/hr) 300-700
Retort temperature ('F) 1200-1400
540 560 580 450 680
1400 1250 1350 1350 1386
Source: Perry 1974.
4-15
-------
2872g
Table 4-6 Treatment Performance Data for Retorting of K106
Sodium Borohydride Sludge Submitted by Plant C
Constituent
Sample Set No. 1
Mercury
Sample Set No. 2
Mercury
Sample Set No. 3
Mercury
Sample Set No. 4
Mercury
Sample Set No. 5
Mercury
Sample Set No. 6
Mercury
Sample Set No. 7
Mercury
aOnly an approximate
concentration.
Untreated waste Treated nonwastewater
Total Total EP toxicity
(rag/kg) (mg/kg) (mg/1)
50,000a 0.5 - 10b <0.0005
50.0003 0.5 - 10b <0.0005
50.0003 0.5 - 10b <0.0005
50.0003 0.5 - 10b 0.0082
50.0003 0.5 - 10b 0.0056
50.0003 0.5 - 10b 0.0036
50,000a 0.5 - 10b <0.0005
value was given for the untreated waste mercury
Source: IMC 1982.
4-16
-------
2872g/p.
Table 4-7 Treatment Performance Data for Stabilization of K106
Collected by EPA at Plant D
Sample Set No. 1
Constituent
BOAT list metals
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Si Iver
Vanadium
Zinc
Constituent
BOAT list metals
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
Untreated
Total
(ppm)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
Sample
Untreated
Total
(ppm)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
waste
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Set No. 2
waste
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Treated nonwastewater
TCLP
(mg/1)
<0.004
0.326
<0.003
<0.02
<0.003
<0.006
0.0096
<0.025
0.007
<0.007
<0.013
Treated nonwastewater
TCLP
(mg/1)
<0.004
0.362
0.004
<0.02
<0.003
<0.0076
0.023
<0.025
<0.006
<0.007
<0.013
Source: USEPA 1988c.
4-17
-------
2872g
BOAT list metals
Table 4-7 (continued)
Sample Set No. 3
Constituent
Untreated waste
Total TCLP
(ppm) (mg/1)
Treated nonwastewater
TCLP
(mg/1)
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
<0.004
0.355
<0.003
<0.02
0.005
<0.006
0.0093
0.027
<0.006
<0.007
<0.013
Source: USEPA 1988c.
4-18
-------
2872g
Table 4-8 Treatment Performance Data for Stabilization of D009
(Contaminated Soil and Debris from Natural Gas Pipeline Industry)
Constituent
Untreated waste
Total TCLP
(mg/kg) (mg/1)
Treated Waste
TCLP
Sample Set No. la
Mercury
Sample Set No. Ib
Mercury
Sample Set No. 2a
Mercury
Sample Set No. 2b
Mercury
Sample Set No. 2c
Mercury
Sample Set No. 3a
Mercury
Sample Set No. 3b
Mercury
Sample Set No. 4a
Mercury
Sample Set No. 4b
Mercury
26
26
0.17
0.17
24.2 0.16
24.2 0.16
24.2 0.16
89
89
33.9
33.9
0.03
0.031
0.04
0.167
0.045
0.04
0.0546
0.04
0.0744
aRange of 2 or 3 reported measurements.
Source: HWTC 1989a,b.
4-19
-------
2872g/p.
(VJ
Table 4-9 Performance Data for Sulfide Precipitation Treatment of K071 Wastewaters Collected by EPA at Plant E
ANALYTICAL DATA:
BOAT list constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
DESIGN AND OPERATING
Parameter
Excess sulfide
Samnle
Untreated
wastewater
(mg/1)
<0.2
0.248
<0.03
<0.06
0.097
<0.66
23.7
0.157
0.148
<0.04
0.615
PARAMETERS:
Set 11
Treated
wastewater
(mg/1)
<0.2
0.103
<0.06
0.553
<0.16
<1.32
0.028
0.275
<0.1
<0.08
0.047
S article
Untreated
wastewater
(mg/1)
<0.1
0.226
<0.06
0.189
<0.16
<1.32
9.25
<0.26
0.1
<0.08
0.88
Set 12
Treated
wastewater
(mg/1)
<0.1
0.158
<0.06
<0.12
<0.16
<1.32
0.027
<0.26
<0.1
<0.08
<0.04
Sanrcle Set #3
Untreated
wastewater
(mg/1)
<0.1
0.293
<0.06
<0.12
<0.16
<1.32
77.2
<0.26
0.12
<0.08
0.535
Treated
wastewater
(mg/1)
<0.1
0.144
<0.06
<0.12
<0.16
<1.32
0.028
<0.26
<0.1
<0.08
0.064
Filter cake (K106)a
Total
(mg/kg)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Operating values
Design value
>40 mg/1
Sample Set #1
85 mg/1
Sample Set #2
101 mg/1
Sample Set
96 mg/1
13
aOnly one sample of the filter cake (K106) was collected.
Source: USEPA 1988b.
-------
5. DETERMINATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
(BOAT)
This section presents the rationale for the determination of best
demonstrated available technology (BOAT) for mercury-containing
nonwastewaters and wastewaters. To determine BOAT, the Agency examines
all available performance data for the technologies that are identified
as demonstrated for each treatability group to determine whether one of
these 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 BOAT Treatment Standards (USEPA 1989a).* BOAT must be
specifically defined for all streams associated with the management of
the listed waste or wastes; this includes the original waste as well as
any residual waste streams created by the treatment process.
The technology that performs best on a particular waste or waste
subcategory 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 a technology is available, EPA may consider data on the
performance of a waste similar to the waste in question, provided that
the similar waste is at least as difficult to treat.
*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 determined by spiking a sample
with a known amount of the target constituent and then comparing the
result of analysis of the spiked sample with the result from the
unspiked sample.
5-1
286Sg
-------
5.1 BDAT for Nonvastewaters
EPA reviewed the available treatment performance data for
mercury-containing wastes presented in Section 4 to determine whether
they represent the operation of well-designed and well-operated systems
and whether sufficient quality assurance/quality control (QA/QC) data
were collected to assess the accuracy of the treated waste analyses.
Identification of BDAT for nonwastewaters is discussed below for each
treatability group.
5.1.1 Inorganic Mercury Nonwastewaters - High-Mercury Subcategory
EPA has identified several thermal mercury recovery technologies,
including retorting, roasting, batch vacuum or steam distillation, and a
proprietary process as demonstrated technologies for inorganic mercury
nonwastewaters in the High-Mercury Subcategory. The Agency has also
identified thermal processing of mercuric sulfide (cinnabar) ores as a
technology that is used to recover mercury from wastes more difficult to
treat than most inorganic mercury wastes because of the higher mercury
content in these ores than in the mercuric sulfide-containing wastes for
which EPA has waste composition data (see Section 3.2.1).
For treatment of wastes in which mercury is present as metallic
mercury or as inorganic mercury compounds, the Agency has data from five
tests as follows:
• Five sets of performance data (presented in Table 4-1) from
recovery of mercury from cinnabar ores by a thermal treatment
process that is very similar to retorting waste treatment
processes;
• Three sets of performance data from retorting of K106 generated
by hydrazine treatment of mercury-containing wastewaters
(presented in Table 4-3);
5-2
2865g
-------
• Thirty-five sets of performance data from retorting of K106
generated by hydrazine treatment of mercury-containing wastewaters
(presented in Table 4-4);
• Five sets of performance data from retorting of a mixed
K071/K106 waste (presented in Table 4-5) that contained 95 percent
K071 and 5 percent K106 sulfide sludge; and
• Seven sets of performance data from retorting of K106 generated
by borohydride reduction treatment (presented in Table 4-6).
The treatment data presented in Table 4-1 include total composition,
TCLP leachate, and EP leachate data for both the untreated waste and
treated nonwastewater residual as well as total composition data for the
air pollution control wastewaters (primarily SO^ scrubber waters).
Quality assurance/quality control (QA/QC) information was also provided.
The data presented in Table 4-3 include total and EP Toxicity procedure
leachate concentrations for mercury and the other EP metals for the
treated nonwastewater, as well as design and operating information.
QA/QC information (analytical recoveries) was also provided with these
data. The treatment data presented in Table 4-4 include total and EP
Toxicity procedure leachate concentrations for mercury only. QA/QC
information was not provided. The data in Table 4-5 include a range of
total mercury concentrations in the treated nonwastewater for each test,
as well as design and operating data. EPA considered the highest value
of the range in each test as the value that represented treatment
performance for that test. No analytical QA/QC data were provided.
However, from the detail of the analytical method provided in the report,
EPA believes that the data were adjusted for analytical recovery before
presentation in the report. The data in Table 4-6 present the EP
leachate mercury concentration for each sample set for the treated
nonwastewater but only a range of total mercury concentrations for the
seven sample sets. No QA/QC data were provided. However, these data
sets indicate that the performance achieved by retorting K106 borohydride
sludge is similar to the performance achieved by retorting mixed
K071/K106 sludges.
5-3
2865g
-------
The treatment performance data presented in Table 4-1 and Tables 4-3
through 4-5 were adjusted for analytical recovery to take into account
analytical interferences associated with the chemical makeup of the
treated waste samples. In the QA/QC test for analytical recovery, EPA
first analyzes a waste for a constituent and then adds a known amount
(i.e., a spike) of the same constituent to the waste material and
reanalyzes the sample for that constituent. The difference between the
total amount detected after spiking and the concentration detected in the
unspiked sample divided by the amount of spike added is the recovery
value. (If recovery tests are run in duplicate, EPA uses the lower
recovery value.) The reciprocal of the recovery multiplied by the
analytical value obtained during performance testing is the
accuracy-corrected value used in comparing treatment effectiveness and
subsequently in calculating treatment standards. Percent recovery values
for constituents detected in the mercury ores tested are presented in
Appendix A. The accuracy adjustment of performance data for total
mercury for thermal processing of mercury ores is detailed in Table 5-1
(at the end of this section).
The design and operating data provided in Table 4-1 show that the
thermal ore processing system was well operated during the test. Even
though the total composition mercury data from this test show higher
mercury concentrations in the residual from thermal ore processing than
for the K071/K106 retorting test, the EP Toxicity procedure and TCLP
leachates from the ore processing residuals show that mercury leaches
from these residuals at very low levels. The range of TCLP leachate
concentrations for mercury in these residuals, reported in Table 4-1, is
0.0002 to 0.006 mg/1 (ppm). The EP leachate concentrations reported for
mercury in the same table are all below 0.0002 mg/1 (ppm).
The design and operating data presented in Tables 4-3 and 4-4 for the
K106 hydrazine sludge indicate that this retorting test was performed at
a much lower temperature (800-1000°F) than was the test of the mixed
K071/K106 wastes (1250-1400°F). This could account for the poorer
treatment performance in this test.
5-4
2865g
-------
Based on the data presented for thermal treatment of mercury wastes
in Table 5-1, retorting for recovery of mercury has been determined to be
the best technology for treatment of inorganic mercury nonwastewaters.
All of the treatment data for thermal mercury recovery processes
presented in Section 4 show that substantial treatment is achieved based
on the reduction in total, TCLP, and EP leachate mercury concentrations
in the treated nonwastewater compared to that in the untreated waste.
The thermal ore processing technology is used at the one U.S. mine that
is known to process mercury ores. Similar technologies (retorting and
roasting) are used or have been used at several chloralkali facilities in
the U.S. and in Europe to process mercury wastewater treatment sludges.
In addition, comparing the melting/boiling/sublimation/decomposition
temperatures presented in Table 5-2 (i.e., for inorganic mercury compounds
known to be present in inorganic mercury nonwastewaters) to the operating
temperatures of the retorters/roasters in which K106 and K106/K071 wastes
have been successfully retorted (800 to 1500°F) (Tables 4-1 through
4-5) clearly indicates that the mercury compounds present in the listed
mercury wastes, as well as most mercury compounds listed in Appendix B,
should be amenable to thermal recovery by retorting/roasting. Therefore,
thermal recovery of mercury is available and thus has been determined to
be BOAT for inorganic mercury nonwastewaters. This is in accordance with
the strong policy in RCRA--both in the land ban and in general
provisions--to utilize recovery technologies as the preferred waste
management option.
During the comment period for the proposed rule, EPA received
numerous comments disputing EPA's determination that retorting/roasting
had been demonstrated for high-mercury content nonwastewaters. The
commenters' arguments were based, to a large extent, on the results of a
recent study entitled Test Results for Thermal Desorption Treatment of
K106 Chlorine Production Waste which, was prepared for The Chlorine
Institute (PEI Associates 1989) . This study reported significant
operational problems and poor elemental mercury recovery when pilot-scale
5-5
2865g
-------
retorting experiments of K106 wastes were conducted. Several commenters
have attributed the poor results to the high concentration of chloride
salts present in K106 that likely interfere with the overall
performance. In addition, several commenters expressed concern about
potential increased emissions of mercury and sulfur dioxide as a result
of thermal processing.
EPA has carefully reviewed this PEI study and the various comments
submitted to the Agency concerning the significance of the findings of
the report. A detailed review of this study is provided in a memo from
A. Paintal to the Administrative Record - Docket LD12REF/7.16.2.11. EPA
has determined that the operational and recovery problems experienced can
likely be attributed to inadequate furnace design, operational controls,
and recovery system design. With regard to furnace design and associated
operational controls, EPA believes that multiple hearth furnaces, rather
than the rotary kiln used by PEI Associate, are more appropriate for
retorting K106 wastes based on the results of Perry (1974) and USEPA
(1989g), which indicate that multiple hearth furnaces provide better
control over residence time and eliminate short-circuiting.
With respect to recovery system design, PEI Associates used a design in
which the condenser was placed after the scrubber system. EPA believes
that the appropriate placement of the condenser in the recovery system is
before the scrubber system.
With respect to the potential interference of chloride salts, no
convincing arguments have been made to substantiate the claim that
chloride salts will interfere with the overall performance of the
retorter/roaster. In fact, retorting of a mixed waste composed of
5 percent K106 and 95 percent K071 has been demonstrated in Perry
(1974). EPA believes that since it is demonstrated that mercury can be
removed from this feed material, which has a higher concentration of
chloride salts (because of the K071 waste) than pure K106, chloride salts
should not be a source of major performance impairment. (Untreated K071
wastes contain from 5 to 67 percent sodium chloride (USEPA 1988g).
Untreated K106 wastes contain 0.6 to 4.7 percent chlorides (Chlorine
5-6
2865g
-------
Institute 1988)). In addition, Perry (1974) reported that acid
pretreating of the sludge prior to retorting increased the mercury
removal from the waste. Although the reason(s) for this increase in
effectiveness was not identified, the study results indicate that
pretreating the waste can improve its amenability to treatment.
With respect to concerns about increased air emissions, EPA fully
expects that both mercury and sulfur dioxide emissions can be effectively
controlled by well-designed and well-operated air pollution control
equipment that allows for recovery of mercury. Perry (1974) reported
greater than 90 percent removal of mercury from the condenser exhaust as
it passed through a chilled water heat exchanger and a Brink demister.
Perry (1974) also reported dust plugging problems in the condensers that
might have resulted in lower overall mercury recovery than could be
achieved. Similar dust problems were solved by placing a cyclone
scrubber before the condenser (USEPA 1989g).
EPA believes that existing Clean Air Act (CAA) controls can address
any potential problems. The National Emission Standard for Hazardous Air
Pollutants (NESHAP) for mercury emissions (40 CFR Part 61, Subpart E)
limits mercury emissions from mercury cell chloralkali facilities and
mercury ore processing facilities. However, to ensure that air emissions
of mercury are controlled adequately, the Agency is specifying as part of
BOAT that the retorting/roasting unit (or the facility) be subject to one
or more of the following: (1) a NESHAP for mercury; (2) a best available
control technology (BACT) or LAER standard for mercury imposed pursuant
to a PSD permit; or (3) a State permit that establishes emission
limitations (within the meaning of Section 302 of the Clean Air Act) for
mercury. The Agency believes that with such air emissions controls,
retorting/roasting is a treatment technology that minimizes threats to
human health and the environment and so satisfies the requirements of
Section 3004(m).
5-7
2S6Sg
-------
A discussion of air pollution control technologies capable of meeting
the mercury NESHAP requirements is provided in USEPA 1984.
For P065, EPA has determined that incineration represents BOAT. EPA
believes this is necessary to remove the reactive characteristic of
mercury fulminate and to enable further treatment or recovery of mercury
(USEPA 1990).
5.1.2 Inorganic Mercury Nonwastewaters - Low-Mercury Subcategory
EPA has identified acid leaching as the only demonstrated treatment
technology for inorganic mercury nonwastewaters with total mercury
concentrations too low to be amenable to recovery by thermal recovery
technologies (i.e., the Low-Mercury Subcategory). Evaluation of these
data for proper system design and operation and calculation of
accuracy-adjusted treatment data are included in the BDAT background
document for K071 (USEPA 1988b).
5.1.3 Organic Mercury Nonwastewaters
EPA has identified incineration, retorting, and roasting as
demonstrated technologies for treatment of mercury-containing
nonwastewaters that contain organomercury constituents (such as
phenylmercuric acetate) or that contain mercury in an organic waste
matrix. Data available to the Agency are specifically on incineration of
organic metallic nonwastewaters and retorting of D009 spent catalysts.
Incineration is applicable and demonstrated for treatment of wastes
containing organic and organometallic constituents. Treatment using
incineration technologies will destroy the organic constituents of the
waste. As a consequence of destruction of the organics, incineration
will break the organo-metal bond in the organometallic waste constituents.
5-8
2865g
-------
The metallic part of the organometallic constituents in the waste, as
well as any metals present in the waste, will remain in the residual
(ash) generated, will be removed from the gases exiting the incinerator
by the air pollution control equipment, or will remain in the gases
exiting the incineration system. Therefore, incineration has been
determined to be BOAT for P092 and D009 organic mercury nonwastewaters,
followed by treatment of the ash and scrubber water residuals by the BDAT
specified for inorganic high- or low-mercury nonwastewaters (depending on
mercury concentration in the ash) and mercury-containing wastewaters as
discussed in Sections 5.1.1 and 5.2, respectively.
At least one facility submitted data showing that wastes with
concentrations of semivolatile organics up to 30 percent are currently
being retorted outside the United States. The facility described its
waste as a mercury spent catalyst contaminated with an intermediate
chemical used in the manufacture of polymers. The facility sends this
D009 waste overseas for the purpose of direct retorting of mercury.
Based on this information, EPA believes that retorting/roasting can be
promulgated as an alternative treatment standard for some organometallic
nonwastewater forms of P092 and D009 wastes.
5.1.4 Nonwastewaters Containing Radioactive Materials
In Section 2.3.4, EPA discussed two subcategories of nonwastewaters
containing reactive materials that have been reported to be generated by
DOE. These were described as metallic mercury-containing radioactive
materials and waste hydraulic oil contaminated with metallic mercury and
radioactive materials.
The Agency has no data or information to indicate that thermal mercury
recovery processes that are demonstrated for treatment of inorganic high-
mercury nonwastewaters would be able to separate the mercury from the
5-9
2865g
-------
radioactive material (tritium) that is the contaminant in the metallic
mercury waste generated by DOE. Thus, the Agency believes that
technologies demonstrated for these wastes are the absorption technologies
discussed in Section 3.1.1(7).. Common absorbents used are zinc dust,
calcium disulfide, and flowers of sulfur. EPA prefers amalgamation with
zinc over conventional spill cleanup procedures involving addition of
calcium polysulfide or flowers of sulfur because the use of zinc results
in lower air emissions of mercury.
The Agency currently has no information on whether this procedure
will reduce the overall leachability of mercury. However, the Agency has
determined that this procedure does provide significant treatment because
of the decrease in air emissions, the change in mobility from liquid
mercury to a paste-like solid, and the potential reduction in
leachability due to the amalgamation with zinc. Based on this
information, the general lack of treatment data, the lack of alternative
technologies, and the unique handling problems associated with
radioactivity, the Agency has determined that amalgamation with zinc
represents the best technology for treatment of elemental mercury wastes
contaminated with radioactive materials.
EPA feels that incineration, which is demonstrated for treatment of
nonradioactive organic mercury nonwastewaters, is also demonstrated for
treatment of waste hydraulic oil contaminated with mercury and
radioactive materials (tritium). However, EPA does not expect recovery
technologies to be applicable to the treatment of nonwastewater residuals
generated from incineration treatment of this waste because of the
radioactive nature of the waste. Therefore, the best technology for
treatment of the nonwastewater residuals generated from incineration of
this waste is determined to be acid leaching.
5-10
2865g
-------
5.2 BDAT for Wastewaters
EPA has identified chemical precipitation followed by filtration,
carbon adsorption, and ion exchange as demonstrated technologies for
treatment of mercury-containing wastewaters where the mercury constituent
is inorganic. EPA has identified chemical oxidation followed by chemical
precipitation and filtration, incineration, ion exchange, and carbon
adsorption as demonstrated technologies for the treatment of wastewaters
containing organomercury constituents or inorganic mercury in an organic
waste matrix.
As discussed in Section 4, EPA does not have treatment data for
wastewaters generated from retorting. However, EPA does have chemical
precipitation treatment data for K071 mercury-containing wastewaters,
which are presented in Table 4-9. The Agency has determined that these
wastewaters are at least as difficult to treat as wastewaters generated
from retorting because the concentrations of mercury and other metals are
similar and neither waste contains significant concentrations of any
interfering substances. These wastewaters are also expected to be at
least as difficult to treat as other mercury-containing wastewaters that
would be classified as D009 wastes because of the relatively high
concentration of mercury in the K071 wastewaters and because the Agency
has no data indicating that D009 wastewaters are routinely generated
containing significant concentrations of constituents (such as oil and
grease) that would affect the performance of chemical precipitation
treatment. This technology substantially reduces the concentration of
mercury in wastewaters, as noted in Table 4-9, where untreated mercury
concentrations of as much as 77 mg/1 are treated to 0.028 mg/1.
EPA has no data on the demonstrated adsorption technologies (ion
exchange and carbon adsorption). However, when these technologies are
used, a regenerant solution is produced that either is recycled or must
5-11
2865g
-------
be treated by chemical precipitation. Therefore, the chemical
precipitation treatment standard would ultimately apply to wastewaters
generated by these technologies.
Data collected by the Agency on treatment of K071 wastewater by
sulfide precipitation and filtration are shown in Table 4-9. Operating
data collected during treatment of this waste show that these data
represent the performance of a well-designed, well-operated treatment
system. EPA adjusted the data values based on the analytical recovery
values in order to take into account analytical interferences associated
with the chemical makeup of the treated sample. Accuracy adjustment of
mercury concentrations for these treatment data is detailed in
Table 5-2. The analytical recovery values used in these calculations are
presented Appendix A.
EPA's determination of substantial treatment is based on the observed
reduction in total mercury concentration from 77.2 ppm to 0.028 ppm in
the K071 mercury-containing wastewaters considered by EPA to be similar
to other inorganic mercury-containing wastewaters.
The Agency believes that this reduction in the concentration of
hazardous constituents is substantial and that sulfide precipitation
followed by filtration is available to treat these wastes because it is a
common commercially available wastewater treatment technology.
Therefore, sulfide precipitation followed by filtration represents BDAT
for these wastewaters.
EPA does not have data on the effectiveness of chemical oxidation
treatment of wastewaters contaminated with organics or organomercury
compounds followed by chemical precipitation and filtration to enable the
Agency to compare this treatment to the performance of sulfide
precipitation treatment of inorganic mercury wastewaters. Lacking these
5-12
286Sg
-------
data, EPA has determined that chemical precipitation is also the best
technology for the treatment of organic mercury wastewaters.
Incineration may be required as a pretreatment method for
organometallic wastes to destroy the organics and concentrate the metals
in the residual ash or the incineration scrubber waters. Resulting
scrubber waters would be expected to be free of organics; therefore,
mercury in these wastewaters is then expected to be able to be treated by
chemical precipitation with effectiveness similar to that of treatment of
inorganic mercury wastewaters. Chemical oxidation may also be effective
as a pretreatment method for organics prior to chemical precipitation.
EPA has no data on the demonstrated adsorption technologies (ion
exchange and carbon adsorption), but these technologies ultimately
generate a residual (the spent carbon or ion exchange resin) that must be
thermally processed (incinerated or retorted) to recover mercury. (In
the cases where the mercury is adsorbed as an organomercury compound,
incineration may be the only thermal treatment option.) Therefore,
either retorting/roasting or incineration is ultimately the best
technology for treatment of nonwastewater residuals generated by these
treatment technologies, and the incineration treatment standard also
applies to nonwastewater residuals generated from the use of these
technologies to treat organic mercury wastewaters.
No data are available on the treatment of P065 wastewaters or D009
reactive mercury wastewaters by the demonstrated technologies identified
in Section 3.2.2 (aqueous chemical deactivation and incineration).
However, based on the demonstrated effectiveness of incineration of other
explosive and reactive D001 wastes (USEPA 1989e), the Agency has
determined that BOAT for these mercury nonwastewaters (incineration in
specially-designed units) followed by treatment of scrubber waters
produced from incineration by the BOAT for inorganic mercury wastewaters
5-13
2865g
-------
(chemical precipitation followed by filtration) is BOAT for these mercury
wastewaters (P065 and explosive D009 wastewaters). The determination is
based on the reasons that were discussed in Section 5.1.3 for explosive
mercury nonwastewaters and in Section 5.2 for inorganic mercury
wastewaters.
5-14
2865g
-------
2872g
Table 5-1 Sunmary of Accuracy Adjustment of Treatment Data for Total Mercury
Generated from Thermal Recovery Technologies
Thermal Treatment
Sample Set No. 1
Sample Set No. 2
Sample Set No. 3
Sample Set No. 4
Sample Set No. 5
Retort ina of K106
Sample Set No. 1
Sample Set No. 2
Sample Set No. 3
Sample Set No. 4
Retort ina of K106
Sample Set No. 1
Sample Set No. 2
Sample Set No. 3
Sample Set No. 4
Sample Set No. 5
Sample Set No. 6
Sample Set No. 7
Sample Set No. 8
Sample Set No. 9
Sample Set No. 10
Sample Set No. 11
Sample Set No. 12
Sample Set No. 13
Sample Set No. 14
Sample Set No. 15
Sample Set No. 16
Sample Set No. 17
Sample Set No. 18
Sample Set No. 19
Sample Set No. 20
Sample Set No. 21
Sample Set No. 22
Sample Set No. 23
Sample Set No. 24
Sample Set No. 25
Sample Set No. 26
Sample Set No. 27
Sample Set No. 28
Untreated
waste
concentration
(mg/kg)
Measured
treated waste
concentration
(mg/kg)
Percent
recovery for
treated waste
matrix
Accuracy
correction
factor
Accuracy-
adjusted
concentration
(mg/kg)
of Mercuric Sulfide Ores
625,000
738,000
640,000
473,000
600,000
Hydrazine Sludae
4,300
5,500
2,500
2,000
Hydrozine Sludae
9,825
7,375
8,200
8,750
32,000
27,000
7,875
17,325
7,375
7,125
5.275
5,275
5.400
4,600
3,780
4.390
3,420
4.280
9,640
5,800
6,300
6,933
7,200
8.000
6,200
5,100
5,205
9,100
45
42.4
36
23
11
(Plant B)
100
90
47
41
(Plant B-2)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
113
113
113
113
113
89
89
89
89
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.0
1.0
1.0
1.0
1.0
1.12
1.12
1.12
1.12
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
45
42.4
36
23
11
112
101
53
46
167.5
637.5
470.0
375.0
124.0
205.5
40.0
104.0
60.5
45.0
60.0
110.0
27.3
41.8
87.5
41.3
10.5
544.3
362.8
1214.0
124.5
268.0
560.0
240.0
77.5
222.5
104.0
765.0
5-15
-------
2872g/p.
Table 5-1 (continued)
Untreated
waste
concentration
(mg/kg)
Measured
treated waste
concentration
(mg/kg)
Percent
recovery for
treated waste
matrix
Accuracy
correction
factor
Accuracy-
adjusted
concentration
(mg/kg)
Retorting of K106 Hvdrozine Sludge (Plant B-2) (contrd)
Sample Set No. 29 5,650
Sample Set No. 30 2.600
Sample Set No. 31 3,010
Sample Set No. 32 5,480
Sample Set No. 33 6,050
Sample Set No. 34 4,500
Sample Set No. 35 6,100
Retorting of Hlxed K071/K106
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
62.5
52.5
29.5
350.0
51.0
1,564.0
39.2
Sample
Sample
Sample
Sample
Sample
Set
Set
Set
Set
Set
No.
No.
No.
No.
No.
1
2
3
4
5
345
255
290
438
370
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0,
3,
2.
7.
1
,8
.1
.6
.2
.6
NA = Not available. Data from Oxychem 1989 (Plant B-2) and Perry 1974, as presented in Table 4-4
and Table 4-5, respectively, are assumed to have been corrected for accuracy of the
analytical method.
5-16
-------
Table 5-2 Mercury Compounds Known To Be Present in Listed Mercury Wastes
and Their Melting Points, Boiling Points, and Behavior
Mercury compound
(mg/1)
Organic compounds
Phenymercuric acetate
Other mercury compounds
Inorganic compounds
Mercury
Mercuric acetate
Mercurous chloride
Mercuric chloride
Mercury fulminate
Mercury hydroxide
Mercuric hydroxide
Mercuric nitrate
Mercurous oxide
Mercuric oxide
Mercuric sulflde
Listed waste(s) Melting Boiling
containing point point
the compound (8 C)
P092 149
D009
K106, 0009. K071 -38.9 357
0009
D009 303 384
K071, 0009 265 303
P065
K106
K106
D009 79
K106, 0009 100
K106. D009, K071
K106. 0009 446
Behavior Solubility
upon heating in water3
(8 C)
sl.s
-
i
Decomposes 250,000
Sublimes 0.2
Sublimes 71,500
Explodes sl.s
-
-
Decomposes v . s .
Decomposes 1
at 100 C
Decomposes 50
above 400 C
Sublimes i
Sources: Singer and Nowak (1978); McGraw-Hill (1982); Weast (1977).
aNumbers given are quantitative solubilities in water (10-25 C). Solubility abreviations
describe the solubility as follows:
1 = insoluble
.sl.s. = slightly soluble
v.s. = very soluble
83678g
5-17
-------
3402g
Table 5-3 Sunmary of Accuracy Adjustment of Treatment Data
for Total Mercury in Wastewaters
Untreated
waste
concentration
(mg/D
Measured
treated waste
concentration
(mg/1)
Percent
recovery for
treated waste
matrix
Accuracy
correction
factor
Accuracy-
adjusted
concentration
(mg/1)
Chemical Precipitation
Sample Set No. 1 23.7
Sample Set No. 2 9.25
Sample Set No. 3 77.2
0.028
0.027
0.028
95
95
95
1.05
1.05
1.05
0.0295
0.0284
0.0295
5-18
-------
6. SELECTION OF REGULATED CONSTITUENTS
In Section 5, the best demonstrated available technology (BOAT) was
determined for each waste treatability group for the mercury-containing
wastes K106, U151, P065, P092, and D009. This section describes the
selection of constituents to be regulated for each waste code. The
selected constituents must be present in the untreated waste at concentra-
tions that are treatable by the chosen BDAT discussed in Section 5.
6.1 Nonwastewaters
In the EPA treatment test of thermal processing of mercuric sulfide
ores, the Agency analyzed the untreated ore samples for BDAT list metals
and BDAT list organic compounds, as well as for total organic carbon
(TOO). No treatable concentrations of organic compounds were detected in
these samples. Thus, these ores are similar to the K106 mercuric sulfide
sludge wastes as generated (see Table 2-4).
The mercuric sulfide ores sampled by EPA were not analyzed for
certain compounds on the BDAT list (specifically, organochlorine
pesticides, phenoxyacetic acid herbicides, organophosphorus insecticides,
PCBs, and dioxins and furans) because the Agency is not aware of any
in-process source of these constituents and would therefore not expect
any of these constituents to be present at treatable concentrations. Two
inorganics other than metals on the BDAT list (fluoride and cyanide) were
not analyzed. Even though these constituents were not analyzed, EPA
would not expect fluoride or cyanide to be present at treatable
concentrations in the wastes tested.
The K106 hydrazine sludge treated at Plant B was analyzed only for
the eight characteristic metals (arsenic, barium, cadmium, chromium,
lead, mercury, selenium, and silver). None of the metals other than
6-1
2866g
-------
mercury were detected at treatable concentrations in this K106 waste.
Results of retorting treatment of the mixed K071/K106 sludge reported in
Literature Source A (see Table 4-5) presented only total mercury
concentrations. However, no treatable concentrations of other BDAT list
constituents were expected to be detected in this waste. Results of
retorting of K106 at Plant C (presented in Table 4-6) also reported only
mercury concentrations. No other BDAT list constituents were expected to
be present at treatable concentrations in this waste.
Upon analysis of data on characterization and treatment of K071 and
K106 wastes generated in the mercury cell chloralkali process and
available information about this process, EPA concludes that mercury is
the only BDAT list constituent expected to be routinely present in wastes
from this process. Thus, the Agency has determined that mercury is the
only regulated constituent for K106.
For P065, P092, and U151, mercury is expected to be the only BDAT
list metal constituent of the waste (unless the wastes are mixed with
other listed or characteristic hazardous wastes, in which case other
treatment standards would also apply). P092 is also expected to contain
organic BDAT constituents (benzene, in particular). Mercury has been
selected as the only regulated constituent for these U- and P-code
mercury-containing wastes. No data are available to EPA on the treatment
of organics in P092 wastes. However, the Agency expects the organic
constituents of P092 to be destroyed by incineration of P092 wastes,
which is required as a method of treatment. EPA also expects that the
fulminate constituent of P065 (mercury fulminate) and the reactive
constituents of D009 reactive wastes will be destroyed by incineration,
which is required as a method of treatment for organic mercury wastes.
Incineration also removes the reactivity characteristic associated with
these wastes.
6-2
2866g
-------
Mercury has also been selected as the only constituent for regulation
for D009 wastes. EPA does not have sufficient characterization data for
D009 wastes to determine whether these wastes commonly contain other BDAT
list constituents at treatable concentrations. If these wastes contain
organic constituents, EPA believes that these constituents will be
destroyed by incineration, which is a required method of treatment for
organic D009 nonwastewaters.
6.2 Wastevaters
EPA does not have data on the composition or treatment of K106
wastewaters generated from retorting. However, EPA does have data that
indicate that mercury is the only BDAT constituent present in wastewaters
generated from recovery of mercury from mercuric sulfide ores in a
multiple-hearth furnace (see Table 4-1). EPA would not expect any BDAT
constituent other than mercury to be present in treatable quantities in
the K106 wastewater for reasons already presented in the discussion of
nonwastewaters. Mercury has therefore been selected as the only
regulated constituent for K106 wastewaters.
Mercury has been selected as the only regulated constituent in P065,
P092, U151, and D009 wastewaters. Mercury is the only constituent for
which these wastes are listed and is the only BDAT list constituent
expected to be present in these wastes, with the following exceptions:
If these wastes are mixed with other listed or characteristic
hazardous wastes, other appropriate treatment standards would also
apply.
For P092 and organic D009 wastes, organic constituents will be
present; incineration is required as a method of treatment for
these organics.
For P065 (which may be reactive) and reactive D009 wastes,
incineration is required as a method of treatment for the
reactivity characteristic of these wastes.
6-3
28668
-------
7. CALCULATION OF TREATMENT STANDARDS
This section presents the calculation of the proposed numerical
treatment standards for K106, P065, P092, U151, and D009 wastes using the
treatment data presented for the best demonstrated available
technologies, as determined in Section 5. In Section 6, mercury was
selected as the only regulated constituent for both nonwastewater and
wastewater forms of the wastes.
The Agency bases treatment standards for regulated constituents on
the performance of well-designed and well-operated BDAT 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.
BDAT standards are determined for each constituent by multiplying the
arithmetic mean of accuracy-adjusted constituent concentrations detected
in treated waste by a "variability factor" specific to each constituent
for each treatment technology defined as BDAT. Accuracy adjustment of
performance data was discussed in Section 5 in relation to defining
BDAT. Variability factors account for normal variations in the
performance of a particular technology over time. They are designed to
reflect the 99th percentile level of performance that the technology
achieves in commercial operation. (For more information on the
principles of calculating variability factors, see EPA's publication
Methodology for Developing BDAT Treatment Standards (USEPA 1989a).)
Details on the calculation of variability factors for mercury-containing
nonwastewaters and wastewaters are presented in this section.
Where EPA has identified BDAT for a particular waste, but because of
data limitations or for some other compelling reason cannot define
specific numerical treatment standards for that waste, the Agency can
7-1
2867g
-------
require the use of that treatment process as a technology standard. The
rationale for specifying technology standards for certain mercury wastes
or waste groups, either in lieu of or in addition to numerical treatment
standards, is also discussed in this section.
7.1 Wastewaters
7.1.1 KL06, P065, P092, and U151 Vastewaters
EPA collected three sets of untreated and treated K071 wastewater
data from one facility using sulfide precipitation followed by
filtration. The following steps were taken to derive the numerical BDAT
treatment standards for K106, P065, P092, and U151 wastewaters:
• Accuracy-corrected constituent concentrations were calculated
for mercury. These calculations are presented in Table 5-2.
• The Agency evaluated the data collected from the sulfide
precipitation treatment system to determine whether any of the
data represented poor design or poor operation. The available
design and operating data show that all three data sets collected
from the Agency testing for wastewater represent the performance
of a well-designed, well-operated system.
• An arithmetic average concentration level and a variability
factor were determined for the BDAT list constituent (i.e.,
mercury) regulated in this waste.
• The BDAT treatment standard for mercury was determined by
multiplying the average accuracy-corrected total concentration by
the variability factor, which has been calculated to be 1.05.
Table 7-1 (at the end of this section) summarizes the calculation of
the numerical treatment standards for K106, P065, P092, and U151
wastewaters. For all wastewater forms of K106, P065, P092, and U151, EPA
is promulgating a treatment standard of 0.030 mg/1. The treatment
standard is based on the performance of sulfide precipitation treatment
of K071 wastewaters. Some mercury-containing wastewaters may require
7-2
2867g
-------
additional or different treatment trains in order to treat other metals
or organics that may interfere with the treatment of mercury.
Pretreatment by an oxidation step (with reagents such as hydrogen
peroxide or sodium hypochlorite) or incineration may be necessary to
treat the organics in P092 wastewaters. Pretreatment by aqueous
chemical deactivation or by incineration in specially-designed thermal
treatment units may be necessary to treat reactive constituents in P065
wastewaters. The treatment standard for K106, P065, P092, and U151
wastewaters is presented in Table 7-3 at the end of this section.
EPA is specifying further that, for treatment standards expressed as
methods of treatment, certain regulatory conditions must be met.
Incinerators must be operated in accordance with the provisions under
40 CFR Part 264, Subpart 0, or Part 265, Subpart 0. Also, EPA is
specifying that, as part of the BOAT, the retorting/roasting unit (or
facility) must be subject to one or more of the following: (1) NESHAP
for mercury, (2) a PDS permit, or (3) a State permit that establishes
emission limitations pursuant to Section 302 of the Clean Air Act for
mercury.
The Agency believes that with such air emission controls retorting is
a treatment technology that minimizes threats to human health and the
environment and so satisfies the requirements of section 3004(m). (The
Agency's authority to impose these conditions on performance of a mercury
retorting device comes directly from its authority under section 3004(m)
to establish methods of treatment. EPA is indicating here that part of
the designated method includes operating pursuant to standards that
prevent cross-media contamination. Such standards are enforceable under
RCRA pursuant to the authority in section 3008(a).)
7-3
2667 g,
-------
7.1.2 D009 Wastewaters
For D009 wastewaters, EPA proposed two regulatory options. One
regulatory option would have required treatment of these wastes to comply
with a treatment standard of 0.030 mg/1. The second regulatory option
was to require treatment of these wastes to meet a treatment level of
0.20 mg/1 (the toxic characteristic level for mercury). In the proposed
rule, EPA solicited comments on the merits of each of these approaches.
The Agency received many comments and reviewed each carefully before
deciding to regulate D009 wastewaters at the characteristic level of
0.20 mg/1. Even though the data available to EPA indicate that a
treatment standard of 0.030 mg/1 is achievable for many D009 wastewaters,
EPA is adopting the characteristic level of 0.20 mg/1 as the treatment
standard for D009 wastes for reasons outlined in Section III.D of today's
final rule for Third Third wastes. In addition, available data indicate
that even the most difficult to treat D009 wastewaters can be treated to
the characteristic level of 0.20 mg/1. The treatment standard for D009
wastewaters is presented in Table 7-4.
7.2 Nonwastevaters
For nonwastewater forms of K106, U151, P065, P092, and D009, EPA is
establishing two general mercury subcategories: a High-Mercury
Subcategory and a Low-Mercury Subcategory. A total mercury concentration
of 260 mg/kg has been established to classify these mercury wastes into
one of these two subcategories and to determine compliance with the
treatment standards.
The retorting performance data from K071/K106 were used to determine
a level of mercury that would classify a waste as either a high-mercury
waste or a low-mercury waste. EPA has determined that the cutoff level
is 260 mg/kg. This is the lowest untreated waste mercury concentration
7-4
2867g
-------
for which retorting was demonstrated (i.e., 255 mg/kg rounded to
260 mg/kg) with approximately 99 percent recovery of mercury. This
cutoff level was determined from retorting a mixed K106/K071
nonwastewater (Table 4-5) (a difficult waste to retort, as discussed
earlier) and is a far lower feed concentration than all other retorting
data (Tables 4-1, 4-3, and 4-4), in which untreated mercury total
composition always exceeds 2,500 mg/1.
Also, the Agency is setting additional restrictions for the disposal
of treatment residues resulting from incinerators, retorters, or
roasters. These additional restrictions are expressed as a requirement
for further treatment (e.g., further retorting) or a requirement for
compliance with a maximum concentration of leachable mercury acceptable
for disposal (e.g., TCLP mercury leachate below 0.20 mg/1 for residues
from retorters and roasters). EPA believes these additional requirements
will adequately minimize the commenters' concern of having a more
leachable mercury in incinerated, retorted, or roasted wastes. The
Agency's authority to impose these additional conditions comes directly
under Section 3004(m).
7.2.1 K106 and U151 Nonwastewaters
For nonwastewater forms of K106 and U151 in the High-Mercury
Subcategory, EPA is promulgating a treatment standard of retorting/
roasting. Nonwastewater residues from retorting/roasting are not
prohibited from land disposal unless they leach mercury above 0.20 mg/1,
as measured by TCLP. Nonwastewater residues unacceptable for land
disposal (i.e., those that leach mercury at levels exceeding 0.20 mg/1)
are required to comply with the appropriate standards (i.e., High- or
Low-Mercury Subcategory) as a prerequisite for land disposal. It is
impermissible to dilute a High-Mercury Subcategory waste to reduce the
concentration to less than 260 mg/kg.
7-5
2867g
-------
For nonwastewater forms of K106 and U151 that are not residues from
retorting/roasting and are in the Low-Mercury Subcategory, EPA is
transferring the performance of acid leaching treatment followed by
sulfide chemical precipitation of K071 nonwastewaters to these inorganic
mercury nonwastewaters. The BOAT treatment standard for these wastes is
0.025 mg/1 mercury as measured by the TCLP leachate. Residues from this
acid leaching process must be evaluated for mercury content to determine
whether they must undergo roasting/retorting. Treatment standards for
K106 and U151 nonwastewaters are summarized in Table 7-5-A, 7-5-B, and
7-5-C.
7.2.2. P065 and P092 Nonwastewaters
For P065 and P092 nonwastewaters, the BOAT treatment standard is
incineration for the carbon-mercury compounds. Alternatively, EPA is
promulgating retorting or roasting for P092 nonwastewaters. Incinerator
nonwastewater residues equal to or above 260 mg/kg mercury are considered
to be in the High-Mercury Subcategory and must be recovered by retorting
or roasting. Incinerator nonwastewater residues below 260 mg/kg are
considered to belong to the Low-Mercury Subcategory and are not
prohibited from land disposal unless they leach mercury above 0.025 mg/1
(as measured by the TCLP). Nonwastewater residues from retorting/roast-
ing operations are not prohibited from land disposal unless they leach
mercury equal to or above 0.20 mg/1 (as measured by the TCLP). Retorting/
roasting residues unacceptable for land disposal (i.e., above 0.20 mg/1)
are required to comply with the applicable standards for the High- or
Low-Mercury Subcategory. P065 and P092 scrubber waters generated from
incineration, roasting, or retorting must comply with the 0.030 mg/1
wastewater standard (see Table 7-3), which is based on the same
performance data used to develop the existing K071 wastewater standard.
Treatment standards for P065 and P092 nonwastewaters are shown in
Tables 7-6-A, 7-6-B, 7-6-C, 7-6-D and 7-6-E.
7-6
2867g
-------
7.2.3 D009 Nonwastevaters
The BOAT treatment standard for D009 High-Mercury Subcategory
nonwastewaters (i.e., those that contain greater than or equal to
260 mg/kg of mercury) is a combination of the treatment standards for the
high-mercury inorganic nonwastewaters and the organic mercury
nonwastewaters. EPA has determined that retorting or roasting represents
BDAT for D009 high-mercury nonwastewaters containing elemental mercury or
inorganic mercury compounds. Although D009 wastes that contain
organomercury constituents or contain mercury contaminated with organics
can also be retorted/roasted, a pretreatment step may be necessary to
allow recovery of mercury. Incineration has been determined to be BDAT
for organics in this type of D009 nonwastewater and also for
nonwastewater containing organomercury constituents. Since incineration
cannot destroy mercury, but instead concentrates mercury in scrubber
water or ash to levels not expected to be acceptable for land disposal,
the Agency has established additional requirements for the mercury in
these residuals. As a result, the treatment standard for D009
high-mercury nonwastewaters is expressed as either retorting/roasting or
incineration. Incinerator nonwastewater residues that contain
concentrations of mercury greater than or equal to 260 mg/kg are
considered to belong to the High-Mercury Subcategory and must be
retorted/roasted prior to disposal. Nonwastewater residues from
retorting/roasting operations are not prohibited from land disposal
unless they leach mercury above 0.20 mg/1 (as measured by the TCLP).
Retorting/roasting residues unacceptable for disposal (i.e., above 0.20
mg/1 TCLP) are required to comply with the appropriate standards for the
D009 High- or Low-Mercury Subcategory.
For D009 low-mercury nonwastewaters, EPA is promulgating a treatment
standard of 0.20 mg/1, as measured by TCLP (i.e., the toxic
characteristic level for mercury). EPA received very few data on the
proposed standards for D009 wastes. These data were determined to
7-7
2867 g
-------
represent the treatment of mercury-containing wastes failing the listing
criteria for D009, as measured by TCLP. However, several commenters
supported the regulatory alternative for setting treatment standards for
D009 wastes at the characteristic level. Although data available to EPA
indicate that the lower proposed standard (0.025 mg/1) should be
achievable for D009, EPA acknowledges the commenters' concerns that a
large, diverse number of wastes that qualify as D009 may not be
represented by K071 performance data. EPA is thus withdrawing the
proposed 0.025 mg/1 level (based on K071 performance data). Based on the
available data, EPA believes D009 wastes can be treated to the
characteristic level by treatment technologies such as stabilization or
amalgamation with zinc or tin. EPA is instead promulgating a treatment
standard of 0.20 mg/1 mercury, as measured by TCLP, for these nonmercury
nonwastewaters. BOAT treatment standards for D009 nonwastewaters are
summarized in Tables 7-7-A, 7-7-B and 7-7-C.
Several commenters identified a list of D009 wastes that the
commenters believe meet EPA's criteria for contaminated soil and debris.
The commenters believe that these D009 wastes are not amenable to
retorting/roasting. However, they have proposed alternative treatment
standards based on the use of a chemical decontamination technology. EPA
has been unable to determine whether the alternative chemical
decontamination technology represents BDAT for these wastes. The Agency
believes such demonstration can be made as part of the ongoing regulatory
efforts for contaminated soil and debris. If the technology is
demonstrated, EPA may publish revisions to today's standards for these
wastes.
7.2.4 Nonwastewaters Containing Radioactive Materials
Information provided to EPA by the U.S. Department of Energy (DOE)
indicates the generation of two particular D009 mixed radioactive/
hazardous wastes that contain mercury. This information also suggests
7-8
2867g
-------
that the BDAT technologies and standards for the corresponding
nonradioactive wastes may not be applicable to these mixed wastes. The
Agency has therefore promulgated alternative treatment standards for
these wastes.
One of the mixed wastes identified is waste elemental mercury
contaminated with radioactive tritium (a radioisotope of hydrogen).
These wastes are often identified as D009 or U151. EPA has determined
that recovery technologies do not represent BDAT for this waste because
the Agency lacks data indicating that these processes would be able to
separate the mercury from the radioactive material, resulting in recovery
of reusable mercury. EPA has identified amalgamation with zinc as a
technology that provides significant treatment to these wastes in terms
of air emissions (thus greatly reducing the toxicity of the wastes) and
also potentially reduces the leachability of mercury by amalgamation.
The BDAT for these wastes is amalgamation with zinc, and the treatment
standard is amalgamation with zinc as a method of treatment.
The second mixed waste identified is a spent hydraulic oil
contaminated with mercury and radioactive tritium. EPA determined that
incineration represents BDAT for this waste because incineration is
demonstrated for nonradioactive organic mercury nonwastewaters. However,
the Agency has modified the nonradioactive organic mercury nonwastewaters
standard for this waste by withdrawing the requirement to recover mercury
from the inorganic residues generated from incineration of this waste.
The Agency is requiring that nonwastewater incineration residues
(incinerator ash and wastewater treatment sludge generated from treatment
of incineration scrubber waters) comply with a TCLP mercury standard of
0.20 mg/1 and that incineration scrubber waters meet the 0.20 mg/1 total
concentration mercury standard for mercury-containing wastewaters.
Treatment standards for mixed radioactive/hazardous mercury wastes are
presented in Tables 7-8 and 7-9.
7-9
2867g
-------
3402g
Table 7-1 Calculation of Numerical Treatment Standard for
K106, P065. P092 and U151 Wastewaters
Constituent
Accuracy-adjusted
treated waste
concentrations8
Mean
treated waste
concentration
Variability
factor
Treatment
standard
Wastewater
Mercury (mg/1) 0.0295 0.029 1.05 0.030
0.0284
0.0295
See Table 5-2.
7-10
-------
1412g
Table 7-2 Calculation of Numerical Treatment Standard for Low-Mercury
Subcategory Nonwastewaters3
Sample
Data source no.
Plant A.I 1
2
3
4
5
6
7
Plant A. 2 1
2
3
4
5
6
7
B
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Accuracy-corrected TCLP
or EP concentration
(mg/1) Average
0.0003 0.0043
<0.0002
-
0.0002
0.0005
0.0017
<0.0002
-
-
0.008
-
<0.002
<0.002
0.007
0.002
<0.002
0.012
0.003
0.004
0.002
<0.002
<0.002
<0.002
0.001
0.003
<0.001
<0.002
<0.002
<0.002
<0.002
<0.002
<0.001
<0.001
<0.002
<0.002
<0.002
<0.001
Treatment
Variability standard
factor (mg/1)
5.47 0.025
a8ased on transfer of performance data from acid leaching of K071 nonwastewater wastes followed
by chemical oxidation and sludge/dewatering/acid washing (USEPA 1988b).
7-11
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Accuracy-corrected TCLP
or EP concentration
(mg/D
0.002
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.002
0.001
0.002
0.001
0.009
<0.001
0.012
0.001
<0.001
-
-
-
-
-
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
7-12
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
Accuracy-corrected TCLP
or EP concentration
(mg/1)
<0.001
<0.001
<0.001
0.001
0.004
«=0.001
0.001
0.001
0.004
<0.001
<0.001
<0.001
-
•
0.008
<0.001
0.001
0.001
0.007
-
<0.001
0.006
0.005
0.009
0.001
0.002
<0.001
0.002
0.002
0.004
0.002
0.002
0.001
0.001
0.001
0.005
0.005
0.003
0.003
0.002
7-13
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
149
150
151
Accuracy-corrected TCLP
or EP concentration
(mg/D
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.001
-
<0.001
0.003
0.006
<0.001
0.002
<0.001
<0.001
0.002
<0.001
<0.001
<0.001
0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.003
0.003
0.001
0.006
0.003
<0.001
0.001
<0.001
<0.001
<0.002
0.003
7-14
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 152
153
154
155
156
157
156
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
Accuracy-corrected TCLP
or EP concentration
(mg/D
.
-
-
0.002
<0.001
<0.001
<0.001
<0.001
0.001
-
-
-
0.011
<0.001
<0.001
.
0.008
0.007
<0.001
<0.001
-
-
-
0.006
0.007
0.001
<0.001
-
0.004
0.008
0.005
0.003
0.001
0.005
0.007
0.002
-
0.010
0.001
0.008
7-15
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
Accuracy-corrected TCLP
or EP concentration
(mg/D
0.005
0.012
0.002
0.002
-
0.040
-
0.011
-
0.032
0.031
0.014
0.003
0.003
0.012
0.008
0.002
0.007
0.005
0.003
0.012
0.004
0.004
<0.001
0.010
<0.001
0.002
-
0.010
0.010
0.005
0.002
0.002
0.002
0.005
-
0.001
0.003
0.068
0.003
7-16
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
Accuracy-corrected TCLP
or EP concentration
(mg/D
<0.001
0.009
0.009
0.005
0.005
0.003
0.002
0.008
0.002
0.008
0.032
0.012
0.011
0.003
0.006
0.028
0.003
0.001
0.006
<0.001
<0.001
<0.001
0.001
0.003
0.006
0.002
0.001
0.010
0.006
0.005
0.011
0.007
0.011
0.002
-
0.004
0.021
0.005
0.003
-
7-17
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 272
273
274
275
276
277
278
279
280
281
262
283
284
265
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309 .
310
311
Accuracy-corrected TCLP
or EP concentration
(mg/D
0.009
0.004
0.004
-
0.008
0.002
0.001
<0.001
<0.001
<0.001
0.001
0.006
0.004
0.010
0.002
0.003
0.004
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.008
<0.001
0.001
0.008
0.001
0.001
0.003
<0.001
0.002
<0.001
<0.001
<0.001
7-18
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
Accuracy-corrected TCLP
or EP concentration
(mg/D
<0.001
0.002
0.008
0.003
0.005
<0.001
<0.001
<0.001
<0.001
0.004
0.001
0.002
0.001
<0.001
<0.001
0.001
0.002
<0.001
0.002
<0.001
0.004
0.004
<0.001
-
0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.001
0.001
0.001
<0.001
0.001
0.001
<0.001
0.003
<0.001
<0.001
7-19
-------
1412g
Table 7-2 (Continued)
Sample
Data source no.
Plant A. 2 354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
Plant B 1
2
3
4
5
6
7
8
9
10
11
12
13
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.004
0.008
0.001
0.001
<0.001
0.008
<0.001
<0.001
0.004
0.002
0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
0.001
0.003
0.011
0.002
0.0047
0.0208
0.0054
0.0030
0.0096
0.0092
0.0085
0.0175
0.0164
0.0098
0.0140
0.0113
0.0131
7-20
-------
1412g
Table 7-2 (Continued)
Data source
Plant B
Sample
no.
14
15
16
17
18
19
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.0710
0.0480
0.0090
0.0020
0.0661
0.0087
aNote that the treatment standard will be enforced using the TCLP. The value for the treatment
standard was rounded to two significant figures at the end of the calculation.
7-21
-------
Table 7-3 BOAT Treatment Standard for K106,
P065, P092, and U151 Wastewaters
Maximum for any sinele grab sample
Total composition
Regulated constituent (mg/1)
Mercury 0.030
7-22
2667 g,
-------
Table 7-4. BOAT Treatment Standard for D009 Wastewaters
Regulated constituent
Maximum for anv single grab sample
Total composition
(mg/1)
Mercury
0.20
2667g
7-23
-------
Table 7-5-A BDAT Treatment Standard for K106 and U151
[All nonwastewaters in the High-Mercury
Subcategory (i.e., greater than or equal to
260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be subject
to one or more of the following: (a) a National Emissions Standard for
Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best Available Control
Technology (BACT) or a Lowest Achievable Emission Rate (LAER) standard for
mercury imposed pursuant to a Prevention of Significant Deterioration (PSD)
permit; or (c) a State permit that establishes emission limitations (within
meaning of Section 302 of the Clean air Act) for mercury. All wastewater
and nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration of
any applicable subcategories (e.g., High- or Low-Mercury Subcategories).
7-24
2867g
-------
Table 7-5-B BOAT Treatment Standard for K106 and U151
[Nonwastewaters that are residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 rag/kg total mercury)]
Regulated Maximum for any single grab sample
constituent TCLP (mg/1)
Mercury 0.20
7-25
2867g
-------
Table 7-5-C BOAT Treatment Standard for K106 and U151
[Nonwastewaters that are not residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg total mercury)]
Regulated Maximum for any single grab sample
constituent TCLP (mg/1)
Mercury 0.025
7-26
2867g
-------
Table 7-6-A BOAT Treatment Standard for P065
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of mercury content]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
a(IMERC) incineration of wastes containing organics and mercury in units
operated in accordance with the technical operating requirements of 40
CFR 264 Subpart 0 and 265 Subpart 0). All wastewater and nonwastewater
residues derived from this process must then comply with the
corresponding treatment standards per waste code with consideration of
any applicable subcategories (i.e., High- or Low-Mercury Subcategories.)
7-27
2867g
-------
Table 7-6-B BDAT Treatment Standard for P092
[All nonwastewaters that are not incinerator residues
and are not residues from RMERC, regardless of mercury content]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
OR ROASTING/RETORTING (RMERC)b
a(IMERC) incineration of wastes containing organics and mercury in units
operated in accordance with the technical operating requirements of 40
CFR 264 Subpart 0 and 265 Subpart 0). All wastewater and nonwastewater
residues derived from this process must then comply with the
corresponding treatment standards per waste code with consideration of
any applicable subcategories (i.e., High- or Low-Mercury Subcategories.)
(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be
subject to one or more of the following: (a) a National Emissions
Standard for Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best
Available Control Technology (BACT) or a Lowest Achievable Emission Rate
(LAER) standard for mercury imposed pursuant to a Prevention of
Significant Deterioration (PSD) permit; or (c) a State permit that
establishes emission limitations (within meaning of Section 302 of the
Clean Air Act) for mercury. All wastewater and nonwastewater residues
derived from this process must then comply with the corresponding
treatment standards per waste code with consideration of any applicable
subcategories (e.g., High- or Low-Mercury Subcategories).
7-28
2867 g,
-------
Table 7-6-C BOAT Treatment Standard for P065 and P092
[Nonwastewaters that are either incinerator residues or residues
from RMERC, and are in the High-Mercury Subcategory (i.e., greater
than or equal to 260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized mercury
for recovery. The retorting or roasting unit (or facility) must be
subject to one or more of the following: (a) a National Emissions
Standard for Hazardous Air Pollutants (NESHAP) for mercury; (b) a Best
Available Control Technology (BACT) or a Lowest Achievable Emission Rate
(LAER) standard for mercury imposed pursuant to a Prevention of
Significant Deterioration (PSD) permit; or (c) a State permit that
establishes emission limitations (within meaning of Section 302 of the
Clean air Act) for mercury. All wastewater and nonwastewater residues
derived from this process must then comply with the corresponding
treatment standards per waste code with consideration of any applicable
subcategories (e.g., High- or Low-Mercury Subcategories).
7-29
2867g
-------
Table 7-6-D BOAT Treatment Standard for P065 and P092
[Nonwastewaters that are incinerator residues (and are not
residues from RMERC) that are also in the Low-Mercury Subcategory
(i.e., less than 260 mg/kg total mercury)]
Maximum for any single grab-sample
TCLP
Regulated constituent (mg/1)
Mercury 0.025
7-30
2867g
-------
Table 7-6-E BDAT Treatment Standard for P065 and P092
[Nonwastewaters that are residues from RMERC and are in the
Low-Mercury Subcategory (i.e., less than 260 mg/kg total mercury)]
Maximum for any single grab-sample
TCLP
Regulated constituent (mg/1)
Mercury 0.20
7-31
2867g
-------
Table 7-7-A BDAT Treatment Standard for D009
[All nonwastewaters that contain mercury and organics (and are not
incinerator residues) and are also in the High-Mercury Subcategory
(i.e., greater than or equal to 260 mg/kg total mercury)]
INCINERATION OF WASTES WITH ORGANICS AND MERCURY (IMERC)a
OR ROASTING/RETORTING (RMERC)b
a(IMERC) incineration of wastes containing organics and mercury in
units operated in accordance with the technical operating requirements
of 40 CFR 264 Subpart 0 and 265 Subpart 0. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury
Subcategories.)
"(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized
mercury for recovery. The retorting or roasting unit (or facility)
must be subject to one or more of the following: (a) a National
Emissions Standard for Hazardous Air Pollutants (NESHAP) for mercury;
(b) a Best Available Control Technology (BACT) or a Lowest Achievable
Emission Rate (LAER) standard for mercury imposed pursuant to a
Prevention of Significant Deterioration (PSD) permit; or (c) a State
permit that established emission limitations (within meaning of Section
302 of the Clean Air Act) for mercury. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury
Subcategories).
7-32
28676
-------
Table 7-7-B BDAT Treatment Standard for D009
[All nonwastewaters that are inorganics (including incinerator residues
and residues from RMERC) and are in the High-Mercury Subcategory
(i.e., greater than or equal to 260 mg/kg total mercury)]
ROASTING OR RETORTING (RMERC)a
a(RMERC) retorting or roasting in a thermal processing unit capable of
volatilizing mercury and subsequently condensing the volatilized
mercury for recovery. The retorting or roasting unit (or facility)
must be subject to one or more of the following: (a) a National
Emissions Standard for Hazardous Air Pollutants (NESHAP) for mercury;
(b) a Best Available Control Technology (BACT) or a Lowest Achievable
Emission Rate (LAER) standard for mercury imposed pursuant to a
Prevention of Significant Deterioration (PSD) permit; or (c) a State
permit that established emission limitations (within meaning of Section
302 of the Clean Air Act) for mercury. All wastewater and
nonwastewater residues derived from this process must then comply with
the corresponding treatment standards per waste code with consideration
of any applicable subcategories (e.g., High- or Low-Mercury
Subcategories).
7-33
2867g
-------
Table 7-7-C BOAT Treatment Standard for D009
[All nonwastewaters in the Low-Mercury Subcategory
(i.e., less than 260 mg/kg total mercury)]
Regulated Maximum for any single grab sample
constituent TCLP (mg/1)
Mercury 0.20
7-34
2867g
-------
Table 7-8 BOAT Treatment Standards for D009 and U151
Elemental Mercury Contaminated with Radioactive Materials
AMALGAMATION WITH ZINC AS A METHOD OF TREATMENT FOR NONWASTEWATERS3
aAny wastewaters must comply with the appropriate wastewater standard
(for D009 or U151).
7-35
2867g
-------
Table 7-9 BOAT Treatment Standard for D009 Hydraulic Oil
Contaminated with Mercury and Radioactive Materials
INCINERATION AS A METHOD OF TREATMENT WITH INCINERATOR RESIDUES
MEETING 0.2 MG/L AS MEASURED BY THE TCLP
7-36
2867g
-------
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, D.C.: American Public Health Association.
Chemfix. 1989. Data submission for the Third Third Proposed Rule.
Docket No. LD12-00073.
Chlorine Institute. 1988. Waste characterization data for K106 wastes,
submitted to Office of Solid Waste. Washington, D.C.: U.S.
Environmental Protection Agency.
Cosan Chemical Corporation. 1989. Response dated April 13, 1989, to
waste questionnaire dated March 9, 1989. Submitted to Office of Solid
Waste. Washington, D.C.: U.S. Environmental Protection Agency.
Drake, H.J. 1978. Mercury. In Kirk-Othmer encyclopedia of chemical
technology. 3rd ed. Vol. 15, pp. 143-156. New York: John Wiley and
Sons.
Easton, D.N. 1988. Management and control of mercury exposure. Am.
Lab. 20(7):66-69.
HWTC. 1989a. Hazardous Waste Treatment Council. Data submission for
the Third Third Proposed Rule. Docket No. LD12-00050.
HWTC. 1989b. Hazardous Waste Treatment Council. Data submission for
the Third Third Proposed Rule. Docket No. ID12-00067.
lammartino, N.R. 1975. Mercury cleanup routes - II. Chem. Eng. 82(3):
36-37.
IMC. 1982. International Minerals and Chemical Corporation. Delisting
petition no. 0321. Submitted by International Minerals and Chemical
Corporation, Electrochemicals Division, Orrington, Maine. Submitted to
Office of Solid Waste. Washington, D.C.: U.S. Environmental
Protection Agency.
McGraw-Hill. 1982. Mercury (element). In McGraw-Hill encyclopedia of
science and technology. 5th ed. New York: McGraw-Hill Book Company.
8-1
3354g
-------
Occidential Chemical Corporation. 1987. Delisting petition for
inorganic waste stream K106: wastewater treatment sludge. Submitted
by Occidental Chemical Corporation, Muscle Shoals plant, Sheffield,
Alabama. Submitted to Office of Solid Waste. Washington, D.C.: U.S.
Environmental Protection Agency.
Oxychem. 1989. Comments to the Third Third Proposed Rule. Docket
No. LD12-00040.
Oxychem. 1990. Response dated February 23, 1990, to waste questionnaire
dated February 8, 1990. Submitted to Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency.
Paintal, A.J. 1990. Memorandum to Jose Labiosa (U.S. Environmental
Protection Agency, Office of Solid Waste). Review of December 1989 PEI
Associates, Inc. report entitled "Test results for thermal desorption
treatment of K106 chlorine production waste." Dated May 7, 1990.
Administrative Record - Docket No. LD13REF/7.16.2.1.
PEI Associates. 1989. Test results for thermal desorption treatment of
K106 chlorine production waste. Data submission by the Chlorine
Institute for the Third Third Proposed Rule. Docket No. LD12-00025.
Perry, R. 1974. Mercury recovery from contaminated waste water and
sludges. EPA 660/2-74-086. National Environmental Research Center.
Project 12040 HDU. Corvallis, Oreg. U.S. Environmental Protection
Agency.
Rosenzweig, M.D. 1975. Mercury cleanup routes - I. Ghent. Eng. 82(2):
60-61.
Singer, W. and Nowak, M. 1978. Mercury compounds. In Kirk-Othmer
encyclopedia of chemical technology. 3rd ed. Vol. 15, pp. 143-
156. New York: John Wiley and Sons.
SRI. 1989. Stanford Research Institute. 1989 directory of chemical
producers, United States of America. Menlo Park, Calif. Stanford
Research Institute.
U.S. Army. 1984. Military explosives. Department of the Army technical
manual TM 9-1300-214, as revised January 30, 1987. Washington, D.C.:
Headquarters, Department of the Army.
U.S. Bureau of Mines. 1985. Mercury: A chapter from mineral facts and
problems, 1985 edition. Preprint from Bulletin 675. Washington, D.C.:
U.S. Department of the Interior.
8-2
335<.g
-------
USEPA. 1984. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. Review of national emission standards for
mercury. EPA-450/3-84-014. Research Triangle Park, N. C.: U.S.
Environmental Protection Agency.
USEPA. 1985. U.S. Environmental Protection Agency, Office of Solid
Waste. Characterization of waste streams listed in 40 CFR Section
261: Waste profiles, Volume II. Final report, prepared for Waste
Identification Branch, Characterization and Assessment Division, Office
of Solid Waste. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1986a. U.S. Environmental Protection Agency, Office of Solid
Waste. 1986 national survey of hazardous waste treatment, storage,
disposal, and recycling facilities. Washington, D.C.: U.S.
Environmental Protection Agency.
USEPA. 1986b. U.S. Environmental Protection Agency, Office of Solid
Waste. 1986 national survey of hazardous waste generators.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1988a. U.S. Environmental Protection Agency, Office of Solid
Waste. Generic quality assurance project plan for Land Disposal
Restrictions Program ("BOAT"). Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1988b. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BOAT) background
document for K071. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1988c. U.S. Environmental Protection Agency, Office of Solid
Waste. Onsite engineering report for Waterways Experiment Station for
K106. Draft report. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1989a. U.S. Environmental Protection Agency, Office of Solid
Waste. Methodology for developing BOAT treatment standards.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1989b. U.S. Environmental Protection Agency, Office of Solid
Waste. Treatment technology background document. Washington, D.C.:
U.S. Environmental Protection Agency.
USEPA. 1989c. U.S. Environmental Protection Agency, Office of Solid
Waste. Proposed best demonstrated available technology (BOAT)
background document for K073. Washington, D.C.: U.S. Environmental
Protection Agency.
8-3
335
-------
USEPA. 1989d. U.S. Environmental Protection Agency, Office of Solid
Waste. Onsite engineering waste collection visit report for Mercury
Refining Company, Albany, New York. Washington, D.C.: U.S.
Environmental Protection Agency.
USEPA. 1989e. U.S. Environmental Protection Agency, Office of Solid
Waste. Proposed best demonstrated available technology (BDAT)
background document for ignitable, reactive, and corrosive wastes.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1989f. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for cyanide wastes. Washington, B.C.: U.S. Environmental
Protection Agency.
USEPA. 1989g. U.S. Environmental Protection Agency, Office of Solid
Waste. Onsite engineering report of treatment technology performance
and operation for McDermitt Mine, McDermitt, Nevada. Final report.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1990. U.S. Environmental Protection Agency, Office of Solid
Waste. Final best demonstrated available technology (BDAT) background
document for characteristic ignitable wastes (D001), characteristic
corrosive wastes (D002), characteristic reactive wastes (D003), and P
and U wastes containing reactive listing constituents. Washington,
D.C.: U.S. Environmental Protection Agency.
Versar Inc. 1986. Summary of available waste composition data from
review of literature and data bases for use in treatment technology
application and evaluation for "California List" waste streams.
Contract No. 68-01-7053, final report for Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency.
Weast, R.C., ed. 1977. CRC handbook of chemistry and physics. 58th ed.
Cleveland, Ohio: CRC Press, Inc.
8-4
335
-------
APPENDIX A
QUALITY ASSURANCE/QUALITY CONTROL DATA
-------
APPENDIX A
QUALITY ASSURANCE/QUALITY CONTROL DATA
A.I Analytical Methods
The analytical methods used for analysis of the regulated
constituents identified in Section 5 are listed in Table A-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,
except for the TCLP extraction procedure (published in 51 FR 40643,
November 7, 1986, as Appendix 1 to Part 268 - Hazardous Waste Management
System; Land Disposal Restrictions; Final Rule).
Specific procedures or equipment used for preparing or analyzing the
regulated constituents when alternatives or equivalents are allowed by
SW-846 are listed in Table A-2.
A.2 Accuracy Determination
The accuracy determination for a pollutant is based on the matrix
spike recovery values. The accuracy correction factors were determined
in accordance with the general methodology (see USEPA 1989a). For
example, for most BOAT list metals, actual spike recovery data were
obtained for each individual TCLP sample and the lowest value was used to
calculate the accuracy-corrected value. Table A-3 presents the matrix
spike recoveries and the accuracy correction factor used to correct the
concentration of mercury in K071 mercury-containing wastewaters and
nonwastewaters.
A-l
2869g
-------
2872g
Table A-l Analytical Methods for K071 Wastewaters
Analysis/Methods Method
Mercury In Liquid Waste (Manual Cold-Vapor Technique) 7470
Mercury in Solid or Semisolid Waste (Manual Cold-Vapor 7471
Technique)
TCLP 40 CFR Part
Z68.
Appendix I
A-2
-------
2872g
Table A-2 Procedures or Equipment Used in Mercury Analysis When
Alternatives or Equivalents Are Allowed in the SW-846 Methods
Analysis
Constituent method Equipment
Alternatives or equivalents
allowed by SW-846 method
Specific procedures
or equipment used
Mercury
7470
7471
Perkin Elmer 50A
Operate equipment according
to instructions of instrument
manufacturer.
Equipment was operated using
procedures specified in Perkin
Elmer 50A Instructions Manual.
Use cold vapor apparatus as
described in SW-846 or an
equivalent apparatus.
• Mercury was analyzed by
cold-vapor method using the
apparatus as specified in
SW-846, except that there was
no scrubber.
Prepare samples using the
water bath method or the
autoclave method, both de-
scribed in SW-846.
• Samples were prepared using
the water bath method.
Source: USEPA 1988b. Table B-2.
A-3
-------
287
Table A-3 Matrix Spike Recoveries Used to Correct Analytical Data for K071
Mercury-Containing Wastewaters and Nonwastewaters
Sample Set 16 Sample Set 16 Duplicate Accuracy
BOAT Original amount Spike added Spike result Percent Spike added Spike result Percent correction
constituent found (ng/1) (<*g/l) (ug/1) recovery3 (<*g/l) (ng/1) recovery8 factor
Mercury 1.6 4.0 5.4 95 4.0 5.5 98 1.05
aPercent Recovery = [(Spike Result - Original Amount)/Spike Added].
Accuracy Correction Factor = 100/Percent Recovery (using the lowest percent recovery value).
Source: USEPA 1988b. Table B-4.
-------
APPENDIX B
PROPERTIES AND MAJOR USES OF THE
PRINCIPAL COMPOUNDS OF MERCURY
-------
APPENDIX B
PROPERTIES AND MAJOR USES OF THE
PRINCIPAL COMPOUNDS OF MERCURY
The attached table presents physical-chemical properties and major
uses of the principal mercury compounds. This table was taken from
McGraw-Hill (1982).
B-l
3678g
-------
Table B-l Principal Compounds of Mercury
Compound and formula
Properties and uses
acetamide. HgfNHCOCH,),
- HglCHjCOO),
nium tetrachloromercurate(II)
fihydrate. (NH4UHgCl4)-2H,0
diammine chloride.
\|treory(n) chloride, ammoniated, HgNH,Cl
eieiay e. HgHAsO.
giriom tetrabromomercurale(Il).
Meicurv(II)benzoate.Hg
-------
Table B-l (continued)
Compound and formula
Properties and uses
Mercury(II) sulfide, red, HgS
Mercury(II) thiocyanate, Hg(SCN),
Mercurochrome, CttH7O5Br1Na,HgOH-3H2O
Mercuryd) acetate, Hg,(CH,COO),
Mercury(I) bromide, Hg,Br,
Mercury(I) chlorate,
Mercuryd) chloride,
Mercury! I) chromate, Hg,CrO,
Mercury! I) iodide, rig,!,
Mercury(I) nitrate,
Mercury(I) sulfate, Hg,SO4
Mercury dimethyl, Hg(CH,),
Mercury diphenyl, Hg(CfH,),
Mercury fulminate, HgfCNO),
Mercury methyl chloride, CH,HgCl
Millon's base, (HgJN)OH-2H10
Mercury thiochloride, Hg,S,Cl,
Mercury oxide chloride, [CXHgCDjCl
MercuryUD oxalate, HgC,0,
Cinnabar; red crystals; insoluble in water, acids, and organic tobZ*
solvents: sublimes at 446°C: red form of HgS is the main mercurr °
White powder; only slightly soluble in water; soluble in alcohol; JL*
composes on heating
Disodium 2,7-dibromo-4-hydroxymercurifluorescein; green
soluble in water; insoluble in alcohol, ether, and chloroform;
2% aqueous solution as a general antiseptic
Colorless plates: decomposes by light or in boiling water into Ht ^
HgfCHjCOO),; slightly soluble in water; insoluble in alcohol!»!
ether ^
White powder or tetragonal crystals; becomes yellow on heating ^
white again on cooling; sublimes at 340-350°C; mp 405°C
White crystals: explodes with combustible substances; mp JSpT
(decomposition); soluble in water and alcohol
Calomel: white rhombic crystals: insoluble in water, alcohol, gu
ether: mp 303°C; bp 384°C: becomes black with ammonia (HtCU
2NH,— Hg+ HgNH,Cl+ NH4C1) by yielding finely divided meuL
mercury
Brick-red powder decomposes on heating to yield CrsOj; insoluble •
water and alcohol: soluble in concentrated nitric acid
Yellow amorphous powder; becomes greenish in light (HgII]-»|{|t
Hgl,); orange on heating, but yellow again on cooling: insoluble b
water, alcohol, and ether: sublimes at 110-120°C: mp 290°C (putUI
decomposition): bp 310°C
Short prismatic crystals: soluble in small quantities of warm wu«.
in nitric acid, in boiling carbon disulfide, and in melhylamine, uj
slightly soluble in benzonitrile: hydrolyzes with large quantities tf
water: mp 70°C with decomposition
White crystalline powder: almost insoluble in water: soluble in IM
sulfuric acid and in dilute nitric acid: decomposes on healing
Colorless volatile liquid: very strong poison: bp 92°C; density it 17C
is 3.084 g/cm*
Colorless crystals: mp 122°C: decomposes on heating into mercon
and diphenyl
Dark-brown crystalline powder: explodes when dry under the (ughlefl
shock and by heating
Colorless plates: mp 170°C: very strong poison
Yellow powder: insoluble in water and organic solvents; exchinjr
OH" ions with halide ions, when in contact with aqueous tttit
halide solutions: consists of NHgj-telraeders with positive chnp
at the N atoms (the NHg4-tetraeders are linked together like tbr
SiO4-tetraeders in SiO,, forming a three-dimensional network) nd
OH* ions: the H,O molecules are in holes of the network
Yellow powder: insoluble in water
Colorless crystals: insoluble in cold water: exchanges 1 Cl~ km wid
F- ions
White powder: insoluble in water: used for Eder's solution (decompow-
lion with light)
Source: McGraw-Hill (1982)
B-3
3678g
------- |