MEMORANDUM
TO: Administrative Record cc: J. Strauss
S. Schwartz
5254 File
FROM: Jim Berkes
DATE: May 8, 1990
SUBJECT: Final Treatment Standards for Nonwastewater and Wastewater
Forms of K044, K045, and K047
This memorandum presents a summary of the technical support and
rationale for the development of the treatment standard for nonwastewater
and wastewater forms of K044, K045, and K047.
Pursuant to section 3004(m) of the Resource Conservation and Recovery
Act (RCRA) as enacted by the Hazardous and Solid Waste Amendments (HSWA)
on November 8, 1984, the Environmental Protection Agency (EPA) is
establishing best demonstrated available technology (BOAT) treatment
standards for the listed wastes identified in 40 CFR 261.32 as K044
(wastewater treatment sludges from the manufacturing and processing of
explosives), K045 (spent carbon from the treatment of wastewater
containing explosives), and K047 (pink/red water from TNT operations).
Compliance with the treatment standards being promulgated will be a
prerequisite for placement of these wastes in units designated as land
disposal units according to 40 CFR Part 268. The effective date of these
treatment standards will be June 9, 1990.
K044, K045, and K047 wastes are listed as hazardous because of the
characteristic of reactivity. The Agency believes that technologies
applicable for treatment of these wastes include those that are capable
of rendering the waste nonreactive. Commenters indicated that K044,
K045, and K047 wastes can be treated by technologies such as chemical
oxidation or incineration. Such treatments permanently remove the
reactive characteristic of these wastes by thermal or chemical
destruction.
In the Second Third final rule (53 FR 31158, August 17, 1988), EPA
promulgated a treatment standard of "No Land Disposal Based on
Reactivity" for K044, K045, and K047 nonwastewaters and wastewaters. In
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Administrative Record Page Two
May 8, 1990
today's final rule (Third Third final rule), the Agency is revoking this
standard and is promulgating a treatment standard of "Deactivation
(DEACT) as a Method of Treatment" for K044, K045, and K047 nonwastewaters
and wastewaters. The treatment standard for K044, K045, and K047 wastes
is presented in Table 1. \^
Several commenters had questions on the definition of deactivation.
To clarify this point, the Agency is defining deactivation for K044,
K045, and K047 wastes to be the process of removing the characteristic of
reactivity, by technologies such as incineration or chemical oxidation.
See 40 CFR 268 Appendix VI for a list of technologies that used alone or
in combination can achieve this standard. See also 40 CFR 268.42 Table 1
for a description of the technologies referred to by a five letter
technology code in parentheses. This standard should provide the
treaters of K044, K045, and K047 wastes the ability to use the "best"
treatment technology based on the chemical and physical parameters of the
waste, and any safety considerations.
The BOAT program and EPA's promulgated methodology are more
thoroughly described in two additional documents: Methodology for
Developing BOAT Treatment Standards (USEPA 1988) and Generic Quality
Assurance Project Plan for Land Disposal Restrictions Programs (BOAT)
(USEPA 1987). The petition process to be followed in requesting a
variance from the BOAT treatment standards is discussed in the
methodology document. Additional information on reactive wastes can be
found in the BOAT Background Document for Characteristic Ignitable Wastes
(D001), Characteristic Corrosive Wastes (D002), Characteristic Reactive
Wastes (D003), and P and U Wastes Containing Reactive Listing
Constituents (USEPA 1990).
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TABLE 1 BOAT TREATMENT STANDARD FOR K044, K045, AND K047
[Nonwastewaters and Wastewaters]
(REVISED FROM NO LAND DISPOSAL)
DEACTIVATION (DEACT) AS A METHOD OF TREATMENT*
* See 40 CFR 268 Appendix VI for a list of applicable technologies that
used alone or in combination can achieve this standard. See also 40
CFR 268.42 Table 1 for a description of the technologies referred to
by a five letter technology code in parentheses.
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REFERENCES
USEPA. 1987. U.S. Environmental Protection Agency. Generic quality
assurance project plan for land disposal restrictions program
(BOAT). EPA/530-SW-87-011. Washington, D.C.: U.S. Environmental
Protection Agency, Office of Solid Waste.
USEPA. 1988. U.S. Environmental Protection Agency. Methodology for
developing BOAT treatment standards. Washington, D.C.: U.S.
Environmental Protection Agency.
USEPA. 1990. U.S. Environmental Protection Agency. Best demonstrated
available technology 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, B.C.: U.S. Environmental
Protection Agency.
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