FINAL

BEST DEMONSTRATED AND AVAILABLE TECHNOLOGY (BOAT)

               BACKGROUND DOCUMENT

                       FOR

  WASTES FROM THE PRODUCTION OF EPICHLOROHYDRIN

                      K017
                  Richard Kinch
       Acting Chief, Waste Treatment  Branch
                    Elaine  Eby
                 Project Manager
       U.S.  ENVIRONMENTAL PROTECTION AGENCY
              Office of Solid Waste
                401 M Street,  S.W.
             Washington, D.C.  20460
                     May 1990

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                              TABLE OF CONTENTS


                                                                          Page

1.0       INTRODUCTION	           1-1

2.0       INDUSTRY AFFECTED AND WASTE CHARACTERIZATION  	           2-1
          2.1   Industry Affected and Process Description  ....           2-1
          2.2   Waste  Characterization   	           2-4

3.0       APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES  .  .           3-1
          3.1   Applicable Treatment Technologies  	           3-1
                3.1.1   Nonwastewaters	           3-1
                3.1.2   Wastewaters   	           3-3
          3.2   Demonstrated Treatment Technologies  	           3-3
                3.2.1   Nonwastewaters	           3-3
                3.2:. 2   Wastewaters   	           3-4

4.0       TREATMENT PERFORMANCE DATA	      4-1
          4.1   Treatment of Organic Constituents  in Nonwastewaters         4-1
          4.2   Treatment of Organic Constituents  in Wastewaters            4-3

5.0       IDENTIFICATION OF THE BEST DEMONSTRATED AND AVAILABLE
          TECHNOLOGY  (BOAT) 	           5-1
          5.1   Review of Treatment Performance Data   	           5-2
          5.2   Accuracy Correction of Treatment Performance Data           5-2
          5.3   Best Demonstrated Technologies  for K017	           5-3
          5.4   Available Treatment Technologies   	           5-4

6.0       SELECTION OF REGULATED CONSTITUENTS 	           6-1
          6.1   BOAT List Constituents Not  Selected for Regulation          6-2
                6.1.1   BOAT List Constituents Not  Analyzed for  the
                       Untreated Waste   	           6-2
                6.1.2   BOAT  List Constituents for  Which Detection
                       Limits  or Analytical Results Were Not Obtained
                       Due  to  Analytical  Problems	           6-2
                6.1.3   BOAT  List Constituents for  Which Available
                       Treatment Performance Data  Did  Not  Show
                       Effective Treatment  by BOAT  	           6-3
          6.2   BOAT List Constituents Selected for Regulation   .           6-3
          6.3   Non-BDAT List  Constituents   	           6-3

7.0       CALCULATION OF BOAT TREATMENT STANDARDS 	           7-1

8.0       ACKNOWLEDGEMENTS	           8-1

9.0       REFERENCES	           9-1

APPENDIX A - Waste Characteristics Affecting Treatment Performance
APPENDIX B - Wastewater Treatment Performance Data

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                               LIST OF TABLES
1-1      BOAT TREATMENT STANDARDS FOR KOI7 - NONWASTEWATERS AND
         WASTEWATERS	          1-4

2-1      FACILITIES THAT MAY GENERATE K017, BY STATE AND
         EPA REGION	          2-5

2-2      SUMMARY OF AVAILABLE CHARACTERIZATION DATA FOR K017 .   .          2-6

6-1      STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017  .   .          6-4

6-2      BOAT LIST CONSTITUENTS SELECTED FOR REGULATION IN K017
         NONWASTEWATERS AND WASTEWATERS  	         6-12
                                     ii

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                              LIST  OF  FIGURES



                                                                        Page
                 !

1       PRODUCTION OF EPICHLOROHYDRIN (K017)  	          2-3
                                    iii

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1.0       INTRODUCTION

          The U.S. Environmental Protection Agency (EPA) is establishing best
demonstrated available technology (BDAT) treatment standards for the listed
hazardous waste identified in Title 40, Code of Federal Regulations. Section
261.32 (40 CFR 261.32) as K017, heavy ends (still bottoms) from the
purification column in the production of epichlorohydrin.  These BDAT
treatment standards are being established in accordance with the amendments to
the Resource Conservation and Recovery Act (RCRA) of 1976, enacted by the
Hazardous and Solid Waste Amendments (HSWA) of November 8, 1984.  BDAT treat-
ment standards will be effective no later than May 8, 1990, and on and after
the effective date, compliance with these BDAT treatment standards will be a
prerequisite under 40 CFR Part 268 for placement of the wastes in land dis-
posal units.

          This background document provides the Agency's rationale and techni-
cal support for selecting the constituents for regulation in K017 and for
developing treatment standards for these constituents.  The document also
provides waste characterization data that serve as a basis for determining
whether a variance from a treatment standard may be warranted for a particular
type of K017 that is more difficult to treat than the wastes that were ana-
lyzed in developing the treatment standards for K017.

          The Agency's legal authority and promulgated methodology for estab-
lishing treatment standards and the petition process necessary for requesting
a variance from the treatment standards are summarized in EPA's Methodology
for Developing BDAT Treatment Standards (Reference 8).

          This background document presents the following waste-specific
information:   the number and locations of facilities that may be affected by
the land disposal restrictions for K017; the processes generating this waste;
waste characterization data; the technologies used to treat this waste (or
similar wastes, if any); and the treatment performance data on which the
treatment standards are based.  This document also explains how EPA determines
BDAT, selects constituents for regulation, and calculates treatment standards.
                                      1-1

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          Under 40 CFR 261.32, wastes identified as K017 are listed as fol-
lows:

          K017 - Heavy ends (still bottoms) from the purification column in
                the production of epichlorohydrin.

The Agency believes that there are three facilities manufacturing epichloro-
hydrin in the United States that could potentially generate this listed waste.

          The Agency is regulating three organic constituents in K017
nonwastewaters and wastewaters.  No metal constituents are being regulated in
K017.  To determine the applicability of the treatment standards, wastewaters
are defined as wastes containing less than 1% (weight basis) total suspended
solids1 and  less  than  1%  (weight basis)  total organic  carbon (TOG).  Wastes
not meeting this definition are classified as nonwastewaters and must comply
with the nonwastewater treatment standards.

          The Agency does not have any performance data for treatment of K017.
Treatment performance tests for these wastes have not been pursued since EPA-
approved analytical methods are not available for some of the constituents of
concern in K017.  Additionally, the Agency believes that adequate treatment
performance data are available for other constituents of concern (that do have
EPA-approved analytical methods) from similar wastes.  Therefore, the Agency
is transferring such data from other sources to develop treatment standards
for K017 nonwastewaters and wastewaters.

          For K017 nonwastewaters, BOAT is incineration, based on treatment
performance of this technology on the similar waste F024.  The treatment
standards for organic constituents are based on treatment performance data
     'The  term "total suspended solids"  (TSS)  clarifies  EPA's previously used
terminology of  "total solids" and  "filterable solids."   Specifically,  total
suspended solids is measured by Method 209C  (total suspended solids dried at 103-
105°C)  in Standard Methods for the Examination of Water and Wastewater. Sixteenth
Edition (Reference 10).
                                      1-2

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transferred from EPA's Final Best Demonstrated Available Technology (BOAT)
Background Document For U and P Wastes and Multi-source Leachate CF039') .
Volume C:  Nonwastewater Forms of Organic U and P Wastes and Multi-Source
Leachate (F034) For which There Are Concentration - Based Treatment Standards
(Reference 19).

          For K017 wastewaters, BOAT treatment standards for organic
constituents are based on treatment performance data transferred from EPA's
Final Best Demonstrated Available Technology (BOAT) Background Document For U
and P Wastes and Multi-Source Leachate (F039).  Volume A:  Wastewater Forms of
Organic U and P Wastes and Multi-Source Leachate (F039) For Which There Are
Concentration-Based Treatment Standards.

          Table 1-1 at the end of this section lists the treatment standards
for K017 nonwastewaters and wastewaters.  Treatment standards for organic
constituents regulated in K017 nonwastewaters and wastewaters are based on the
total concentration of each constituent in the waste.

          The units used for total constituent concentration of organic
constituents in K017 nonwastewaters are mg/kg (parts per million on a weight-
by-weight basis).  The units used for total constituent concentration of
organic constituents in K017 wastewaters are mg/1 (parts per million on a
weight-by-volume basis).  If the concentrations of the constituents regulated
in K017 nonwastewaters and wastewaters, as generated, are lower than or are
equal to the promulgated treatment standards, then treatment of the waste is
not required prior to land disposal.
                                      1-3

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                                   Table  1-1

                       BOAT  TREATMENT  STANDARDS  FOR K017

                        NONWASTEWATERS AND WASTEWATERS
                      Maximum for Any Single Grab Sample
                                                         Total Concentration
                                                            Nonwastewaters
BOAT List Constituent                                     	(nig/kg)	

26.  1,2-Dichloropropane                                         18
49.  1,2,3-Trichloropropane                                      28
68.  Bis(2-chloroethyl)ether                                      7.2
                   Maximum for Any 24-Hour Composite Sample


                                                           Total  Concentration
                                                              Wastewaters
BOAT List Constituent                                      	(mg/1)	

26.  1,2-Dichloropropane                                          0.85
49.  1,2,3-Trichloropropane                                       0.85
68.  Bis(2-chloroethyl)ether                                      0.033
                                      1-4

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2.0       INDUSTRY AFFECTED AND WASTE CHARACTERIZATION

          This section describes the industry affected by the land disposal
restrictions for K017 and presents available characterization data for this
waste.

          Under 40! CFR 261.32 (hazardous wastes from specific sources), wastes
identified as K017 are listed as heavy ends (still bottoms) from the
purification column in the production of epichlorohydrin.

2.1       Industry Affected and Process Description

          The Agency estimates that there are three domestic facilities that
produce and purify epichlorohydrin and may potentially generate K017.
Table 2-1 (presented at the end of this section) lists these facilities by
state and EPA region.  These facilities were identified using the updated TSDR
survey database as well as data collected during EPA's listing efforts for
K017  (Reference 6).

          Epichlorohydrin is used mainly as an intermediate for the manufac-
ture of glycerin and epoxy resins.  It is also used in the manufacture of
plasticizers, surfactants, stabilizers, and ion exchange resins.

          Heavy ends (still bottoms) from the purification column in the
production of epichlorohydrin is the waste stream addressed in this
document.  A simplified flow diagram illustrating the manufacturing process
generating epichlorohydrin is presented in Figure 1.

          Epichlorohydrin is produced by the following reaction sequence:

          Step 1:
                  i
              C12    +   H20     	>      HOC1      +       HC1
          (chlorine)   (water)             (hypochlorous    (hydrochloric
                                              acid)             acid)
                                      2-1

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Step 2:
  CH2-CH-CH2C1
(allyl chloride)
     HOC1
    HC1
(hypochlorous
 acid and hydro-
 chloric acid)
                                                    CH2OHCHC1CH2C1  (65-70%) +
                                                     (1,2-dichloropropanol-l)
                                                     CH2C1CHOHCH2C1  (30-55%)
                                                     (1,3- dichloropropanol - 2 )
          Step 3:
                                                              /   \
          CH2OHCHC1CH2C1 + CH2C1CHOHCH2C1 + 2NaOH ......... > 2CH2-CH-CH2C1
          (1,2-dichloropronanol-l)               (epichlorohydrin) + 2NaCl
                       (1,3 -dichloropropanol -2)                    + 2H20

By-products produced in small quantities during the reaction sequence include
1, 2 , 3-trichloropropane and chloro- ethers.

          As shown in Figure 1, a mixture of hypochlorous acid and hydro-
chloric acid reactants is produced by absorbing chlorine in water in a
chlorine absorber.  The resulting acid reactant feed plus allyl chloride are
then fed to the chlorination reactor.  After chlorination, the reaction
mixture (containing the dichloropropanols , some feed materials, and the
reaction by-products) is sent to a separator.  The top aqueous layer
containing hydrochloric and hypochlorous acids is then recycled to the
chlorine absorber, and the bottom organic phase is sent to the
dehydrochlorination reactor, where the dichloropropanols are
dehydrochlorinated using sodium hydroxide.

          The crude epichlorohydrin and calcium chloride mixture from the
dehydrochlorination reactor is sent to a steam stripper.  In the steam strip-
per,  an azeotropic mixture is formed consisting of water and crude epichloro-
hydrin.  This mixture is taken overhead, condensed, and sent to a liquid/ -
liquid separator.

          The wastewater from the bottom of the steam stripper is stripped  in
the aqueous phase stripper, where small amounts of epichlorohydrin are recov-
ered overhead and recycled to the steam- stripper condenser.  The bottom  stream
is discharged as wastewater.
                                      2-2

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                                             Water
                          Hypochlorous
                       and Hydrochloric
                          Acid Recycle
                         Aqueous Phase
          Chlorine
          Absorber

                   Hypochlorous
                 and  Hydrochloric
                     Acid Feed
  Reactor
  Chlorine
         Ally!
       Chloride
	J
        Chlofinotion
          Reactor
ro
                             Oichlorapropanols
                                   HL_
                                    Separator
    Crude
Epichlorohydrin
    plus
   Calcium
   Chloride
                                                                                                                                 Hastewater
                                                                                                                                    from
                                                                                                                                    Steam
                                                                                                                                  Stripper
                                                                             Wastewater
                                                                             (to Aqueous
                                                                               Phase
                                                                              Stripper)
                                                                                                               Wastewater
                                                                                                       Organic Phase
                                                                                                          Stripper
                                                                                                            rr
                                          Organic  Phase
                                Sodium
                               Hydroxide
                                1
                                             Dehydrochlorination
                                                  Reactor
                                                                                          u
                                                                                                                 Crude
                                                                                                              Epichlorohydrin
                                                                                       Purified
                                                                                    Epichlorohydrin

                                                                                    (89% Product)
                                                                Purification
                                                                  Column
                                                                                                                                         Hazardous
                                                                                                                                           Waste
                                                                                                                                           Stream
                                                                                                                                           (KOI 71
                                            figure   1.    Production  of  Epichlorohydrin  (K017)

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          The bottom organic phase from the liquid/liquid separator is fed to
the organic phase stripper where residual water is removed overhead.  The
bottom stream of crude epichlorohydrin is fed to a purification column where
it is purified by fractionation.  Purified epichlorohydrin is distilled
overhead.  The bottom stream from the purification column forms the listed
waste K017.

2.2       Waste Characterization

          Table 2-2 (at the end of this section) presents a summary of the
available characterization data for K017.  Data are presented for BDAT List
constituents and other compounds that are believed to be present or have been
detected in K017.

          As shown in Table 2-2, K017 contains several organic constituents
that could be present at concentrations up to 70%.  These constituents are
1,2-dichloropropane; 1,2,3-trichloropropane; bis(2-chloroethyl)ether;  bis(2-
chloromethyl)ether; epichlorohydrin; and dichloropropanol.   K017 is not
expected to contain metals, based on engineering judgment of the process
generating the waste.
                                      2-4

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                                  Table  2-1




          FACILITIES THAT MAY GENERATE K017,  BY STATE AND EPA KEGION






    Facility                          Location                     EPA Region




Dow Chemical                       Freeport,  TX                         VI




Shell Oil Co.                      Deer Park, TX                        VI




Ciba-Geigy Corp.                   Toms River, NJ                       II
                                      2-5

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                                  Table  2-2

              SUMMARY OF AVAILABLE CHARACTERIZATION DATA FOR K017
BOAT List Constituents

26.  1,2-Dichloropropane
49.  1,2,3-Trichloropropane
68.  Bis(2-chloroethyl)ethere

Other Constituents

Bis(2-chloromethyl)ether0
Epichlorohydrin
Dichloropropanol
Bis-dichloropropyl ether
Bis-tetrachloropropyl ether
Chlorinated Aliphatics
Chloroallyl alcohol
1-Chloropropane
2-Chloropropane
Untreated Waste Concentration (%)
 Source*                  Source"
    0.1-1
  <0.01-70
     14
     14
  <0.01-10
    0-10
  <0.01-50
    10-50
      4
   <0.01-1
    0.1-1
    0.1-1
NA
70
14
14
 2
10
NA
NA
 4
NA
NA
NA
NA - Not available.

•Waste  Profiles  (Reference 18).
"Listing Background Document for K017 (Reference 6).
"Untreated waste concentration for chloroethers  including
 bis(2-chloroethyl)ether and bis(2-chloromethyl)ether combined
 is 14 percent.
                                      2-6

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3.0       APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES

          This section identifies the treatment technologies that are applica-
ble for treatment of K017 and determines which of the applicable technologies
can be considered demonstrated for the purpose of establishing BOAT.

          To be applicable, a technology must theoretically be usable to treat
the waste in question or to treat a waste that is similar in terms of parame-
ters -that affect treatment selection.  (Detailed descriptions of technologies
that are applicable to listed hazardous wastes are provided in EPA's Treatment
Technology Background Document (Reference 9).)  To be demonstrated, a technol-
ogy must be employed in full-scale operation for the treatment of the waste in
question or of a similar waste.  Technologies available only at pilot- or
bench-scale operations are not considered in identifying demonstrated
technologies.

3.1       Applicable Treatment Technologies

          Since K017 contains high concentrations of organic compounds,
applicable treatment technologies include those that destroy, reduce, or
recover the total amount of various organic compounds in the waste.

3.1.1     Nonwastewaters

          The Agency has identified the following treatment technologies as
applicable for nonwastewater forms of K017:  (1) incineration (fluidized-bed,
rotary kiln, and liquid injection); (2) solvent extraction (including critical
fluid extraction) followed by incineration or recycle of the extract; and (3)
total recycle or reuse.  These treatment technologies were identified based on
current literature sources, field testing, and current waste treatment
practices.

          Incineration.  Incineration is a destruction technology in which
energy, in the form of heat, is transferred to the waste to destabilize
chemical bonds and destroy hazardous organic constituents.  In a fluidized-bed
                                      3-1

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incinerator, waste is injected into the fluidized-bed material (generally sand
and/or incinerator ash), where it is heated to its ignition temperature.  Heat
energy from the combustion reactions is then transferred back to the fluidized
bed.  Ash is removed periodically during operation and during bed change-outs.

          In a rotary kiln incinerator, waste is fed into the elevated end of
the kiln, and the rotation of the kiln mixes the waste with hot gases to heat
the waste to its ignition temperature.  Ash is removed from the lower end of
the kiln.  Combustion gases from the kiln enter the afterburner for complete
destruction of waste constituents.  Other waste may also be injected into the
afterburner.

          In a liquid injection incinerator, liquid wastes are atomized and
injected into the incinerator.  In general, only wastes with low or negligible
ash contents are amenable to liquid injection incineration.  Therefore, this
technology generally does not result in the generation of an ash residual.

        .  Combustion gases from the incinerator are then fed to a scrubber
system for cooling and removal of entrained particulates and acid gases, if
present.  In general, with the exception of liquid injection incineration, two
residuals are generated by incineration processes:  ash and scrubber water.

          Solvent Extraction.  Solvent extraction is a separation technology
in which organics are removed from the waste due to greater constituent
solubility in the solvent phase than in the waste phase.  This technology
results in the generation of two treatment residuals:  a treated waste resi-
dual and an extract.  The extract may be recycled or may be treated by
incineration.

          Critical Fluid Extraction.  Critical fluid extraction is a solvent
extraction technology in which the solvent is brought to its critical state to
aid in the extraction of hazardous organic constituents from the wastes.
After the extraction step, the solvent (liquified gas at its critical state)
is brought back to its normal condition in the gaseous state, generating a
small volume of extract that is concentrated in hazardous organic
                                      3-2

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constituents.  This technology results in the generation of two treatment
residuals:  a treated waste and an extract.  The extract may be recycled or
may be treated by incineration.

          Total Recycle or Reuse.  Total recycle or reuse of a waste in the
same process or another process eliminates the generation of the waste and
generates no treatment residuals.

3.1.2     Wastewaters

          Applicable treatment technologies for organics in wastewaters are
discussed in Section 3.0 of EPA's Final Best Demonstrated Available Technology
(BOAT) Background Document For U and P Wastes and Multi-Source Leachate
(F039). Volume A:  Wastewater Forms of Organic U and P Wastes and Multi-Source
Leachate  (F039) For Which There Are Concentration-Based Treatment Standards
(Reference 20).  The Agency has also identified these treatment technologies
as applicable for wastewater forms of K017.

3.2       Demonstrated Treatment Technologies

3.2.1     Nonwastewaters

          The Agency has identified incineration (including rotary kiln,
liquid injection, and fluidized-bed incineration) and total recycle or reuse
as the demonstrated treatment technologies for K017 nonwastewater and
nonwastewater residuals.  The Agency is not aware of any facilities that
treat, on a  full-scale operational basis, K017 or similar wastes using solvent
extraction or critical fluid extraction; therefore, EPA believes that solvent
extraction and critical fluid extraction are not currently demonstrated for
K017.

          Incineration.   Rotary kiln incineration is  demonstrated  on  a full-
scale operational basis for treatment of K107 at at least one facility.
Liquid injection incineration is demonstrated on a full-scale operational
basis for treatment of a similar waste  (F024) at at least four facilities.  In
                                      3-3

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addition, fluidized-bed incineration is demonstrated on a full-scale
operational basis for treatment of a similar waste (F024) at at least one
facility.

          Total Recycle or Reuse.   EPA is aware of at least one facility that
reuses K017 as feed to a thermal oxidation unit that produces acid and heat.

3.2.2     Wastewaters

          The Agency is not aware of any facilities that treat wastewater
forms of K017.  However, the Agency believes that the technologies identified
as applicable in EPA's Final Best Demonstrated Available Technology (BOAT)
Background Document For U and P Wastes and Multi-Source Leachate (F039).
Volume A:  Wastewater Forms of Organic U and P Wastes and Multi-source
Leachate (K039) For Which There Are Concentration-Based Treatment Standards
(Reference 20) are also demonstrated for treatment of the organic constituents
of concern in K017.  The Agency has identified the technologies identified in
Volume A (Reference 20) as demonstrated for wastewater forms of K017.
                                      3-4

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4.0       TREATMENT PERFORMANCE DATA

          The Agency does not have any treatment performance data for treat-
ment of K017 nonwastewaters and wastewaters.  Therefore, treatment performance
data were transferred from other previously tested wastes to develop treatment
standards for K017 nonwastewaters and wastewaters.  The basis for data
transfer and the sources of treatment performance data are discussed below.

          EPA's methodology for transfer of treatment performance data is
provided in EPA's Methodology for Developing BOAT Treatment Standards (Refer-
ence 8).  Transfer of treatment performance data is technically valid in cases
where the untested waste is generated from a similar industry or similar
processing step, or has similar waste characteristics affecting treatment
performance and treatment selection as the tested wastes.  Sources of treat-
ment performance data for potential transfer to K017 nonwastewaters include
wastes previously tested by rotary kiln, fluidized-bed, or liquid injection
incineration.  Sources of treatment performance data for potential transfer to
K017 wastewaters include those wastes and technologies identified in EPA's
Final Best Demonstrated Available Technology (BOAT) Background Document For U
and P Wastes and Multi-Source Leachate (F039). Volume A:  Wastewater Forms of
Organic U and P Wastes and Multi-Source Leachate (K039) For Which There Are
Concentration-Based Treatment Standards (Reference 20).

4.1       Treatment of Organic Constituents in Nonwastewaters

          Wastes previously tested by the Agency by rotary kiln, fluidized-
bed, or liquid injection incineration include:  K001, K019, K024, K037, K086,
K087, K101, K102, F024, K048, and K051.  EPA examined these wastes to identify
the best data source(s), if any, for transfer of treatment performance data to
K017 nonwastewaters.  Specifically, EPA examined whether the untested waste is
(1) generated from similar industries or processing steps, and  (2) whether the
waste has similar waste characteristics affecting treatment performance as
these previously tested wastes.
                                      4-1

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          Of the wastes previously tested by Incineration, two wastes, F024
and K019, are believed to be similar to K017.   F024 and K019 are generated
from the chlorinated organic chemicals industry and are also generated by
distillation, filtration, or some other type of separation process from the
product stream.  K019 is generated from the production of chlorinated ethanes
and contains high concentrations of these constituents.  F024 is generated
from the production of chlorinated organic chemicals having carbon contents of
one to five carbons, and contains high concentrations of these types of
compounds.  In addition, F024 contains high concentrations of the three BOAT
List constituents (1,2-dichloropropane; 1,2,3-trichloropropane; and bis(2-
chloroethyl)ether) present in K017.  K019 contains only one of the BOAT List
constituents contained in K017, at a lower concentration than that in F024.

          As discussed in the Treatment Technology Background Document (Refer-
ence 9), waste characteristics that affect treatment performance for rotary
kiln, fluidized-bed, and liquid injection incineration include the thermal
conductivity of the waste and the boiling points and bond dissociation ener-
gies of the constituents of concern.  (Boiling points and bond dissociation
energies of the constituents of concern in K017 are provided in Appendix A.)
K017 is a sludge as generated and is expected to have a similar thermal
conductivity to those of F024 and K019.  The three BOAT List constituents
present in K017 are also present in F024, and one BOAT List constituent is
present in K019.  Thus, the BOAT List constituents in K017 would have the same
boiling points and bond dissociation energies as those constituents in F024
and K019.  Therefore, based on thermal conductivity, boiling points, and bond
dissociation energies, K017 is expected to be no more difficult to treat than
either F024 or K019.

          Characterization data for K017 shows that K017 nonwastewaters are
comprised primarily of the organic constituents 1,2-dichloropropane;
trichloropropane; bis(2-chloroethyl)ether; bis(2-chloromethyl)ether;
epichlorohydrin; and dichloropropanol.  The BOAT List constituents 1,2-
dichloropropane; trichloropropane; and bis(2-chloroethyl)ether were also found
in untreated F024 at concentrations of up to 23%, 0.9%, and 0.9%,
                                      4-2

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respectively.  The only matching BDAT List constituent found in untreated K019
was bis(2-chloroethyl)ether at a concentration up to 340 ppm (0.034%).

          Based on the similarities discussed above, the treatment performance
of incineration for organic BDAT List constituents in K017 nonwastewaters was
transferred from rotary kiln incineration of F024.

          The treatment standards for organic BDAT List Constituents in K017
nonwastewaters were developed from incineration treatment performance data
transferred from EPA's Final Best Demonstrated Available Technology (BDAT)
Background Document For U and P Wastes and Multi-Source Leachate (¥039).
Volume C:  Nonwastewater Forms of Organic U and P Waste and Multi-Source
Leachate (K039) For Which There Are Concentration-Based Treatment Standards
                  !
(Reference 19).  These data were used for transfer to K017 nonwastewaters
since the Agency believes that this incineration data best represents effluent
concentrations achievable in analysis of organic constituents in incineration
ash.
                  I
4.2       Treatment of Organic Constituents in Wastewaters

          Treatment standards for organic BDAT List Constituents in K017
wastewaters were developed from treatment performance data transferred from
EPA's Final Best Demonstrated Available Technology (BDAT) Background Document
For U and P Wastes and Multi-Source Leachate (F039). Volume A:  Wastewater
Forms of Organic U and P Wastes and Multi-Source Leachate (F039) For Which
There Are Concentration-Based Treatment Standards (Reference 20).

          Treatment performance data from Volume A (Reference 20) are
presented in Appendix C.  These data were used for transfer to K017
wastewaters because the Agency prefers, whenever possible, to use appropriate
wastewater treatment data from well-designed and well-operated wastewater
treatment units, rather than scrubber water concentration data, in setting
BDAT treatment standards.  Additionally, these data represent a specific
wastewater treatment technology as opposed to incineration scrubber water.
                                      4-3

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5.0       IDENTIFICATION OF THE BEST DEMONSTRATED AND AVAILABLE TECHNOLOGY
          (BOAT)

          This section presents the Agency's rationale for determining the
best demonstrated available technology (BOAT) for K017 nonwastewaters and
wastewaters.   BOAT for K017 nonwastewaters has been determined to be incinera-
tion.  BOAT for K017 wastewaters was determined on a constituent-by-
constituent basis and is discussed in EPA's Final Best Demonstrated Available
Technology (BOAT) Background Document For U and P Wastes and Multi-Source
Leachate (F039). Volume A:  Wastewater Forms of Organic U and P Wastes and
Multi-Source Leachate (K039) For Which There Are Concentration-Based Treatment
Standards (Reference 20).

          To determine BDAT, the Agency examines all available treatment
performance data on technologies that are identified as demonstrated for the
waste of concern, or for a waste similar to the waste of concern, to evaluate
whether one or more of the technologies performs significantly better than the
others.  If data are available for only one technology for treating a waste,
then that technology is "best."  When data are available for more than one
treatment technology, the "best" performing treatment technology is usually
determined using a statistical method as discussed in EPA's Methodology for
Developing BDAT Treatment Standards (Reference 8).  In the case of wastewater
treatment data available to the Agency for multi-source leachate (F039)
wastewaters,  found in Volume A (Reference 20), a data hierarchy was
established to determine the best treatment technology for each constituent.

          The treatment technology that is found to perform best on a particu-
lar waste stream is then evaluated to determine whether it is "available."  To
                   I
be available, the technology must (1) be commercially available, and (2)
provide "substantial" treatment of the waste, as determined through evaluation
of treatment performance data that have been corrected for accuracy.  In
determining whether treatment is substantial, EPA may consider data on a
treatment technology's performance on a waste similar to the waste in ques-
tion, provided that the similar waste is at least as difficult to treat.  If
it is determined that the best performing treatment technology is not
                                      5-1

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available, then the next best technology is evaluated to determine whether it
is "available," and so on.

5.1       Review of Treatment Performance Data

          The available treatment performance data referenced in Section 4.0
were reviewed and assessed to determine whether they represent operation of a
well-designed and well-operated system, whether sufficient quality assur-
ance/quality control measures were employed to ensure the accuracy of the
data, and whether the appropriate measures of performance were used to assess
the performance of the treatment technology.  The Agency had no reason to
believe that: the treatment systems represented by these data were not well-
designed and well-operated, or that insufficient analytical quality
assurance/quality control measures were employed in generating the treatment
performance data.  Additionally, the data referenced in Section 4.0 had the
appropriate measures of performance used to assess the treatment performance.

5.2       Accuracy Correction of Treatment Performance Data

          As part of the review of treatment performance data, the data are
adjusted to take into account any analytical interferences associated with the
chemical makeup of the samples.  Generally, performance data are corrected for
accuracy as follows:  (1) a matrix spike recovery is determined, as explained
below, for each BOAT List constituent detected in the untreated or treated
waste; (2) an accuracy correction factor is determined for each of the above
constituents by dividing 100 by the matrix spike recovery (expressed as a
percentage) for that constituent; and (3) the reported concentration of each
BOAT List constituent detected in the untreated or treated waste is corrected
by multiplying the concentration by the corresponding accuracy correction
factor.

          Matrix spike recoveries are developed by analyzing a sample of a
treated waste for a constituent and then re-analyzing the sample after the
addition of a known amount of the same constituent (i.e., spike) to the
sample.  The matrix spike recovery represents the total amount of constituent
                                      5-2

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recovered after spiking minus the initial concentration of the constituent in
the sample, and the result divided by the spike concentration of the
constituent.

          Accuracy correction of the nonwastewater treatment performance data
is discussed in EPA's Final Best Demonstrated Available Technology (BOAT)
Background Document For U and P Wastes and Multi-Source Leachate (F039).
Volume C:  Nonwastewater Forms of Organic U and P Wastes and Multi-Source
Leachate (F039) For Which There Are Concentration-Based Treatment Standards
(Reference 19).

          Accuracy correction of the wastewater treatment performance data is
discussed in EPA's Final Best Demonstrated Available Technology (BOAT)
Background Document For Wastewater Forms of Organic U and P Wastes and Multi-
Source Leachate (F039). Volume A:  Wastewater Forms of Organic U and P Wastes
and Multi-Source Leachate (F039) For Which There Are Concentration-Based
Treatment Standards (Reference 20).

5.3       Best Demonstrated Technologies for K017

          As discussed above, incineration has been determined to be the
demonstrated technology for treatment of organics in nonwastewater forms of
K017.  Because the Agency does not have treatment performance data for any
other technologies for treating K017 nonwastewaters or similar wastes, this
treatment is the best.  Therefore, the best demonstrated technology for K017
nonwastewaters has been determined to be incineration.

          The best demonstrated technologies for treatment of organics in K017
wastewaters are presented and discussed on a constituent-by-constituent basis
in EPA's Final Best Demonstrated Available Technology (BOAT) Background
Document for Uastewater Forms of Organic U and P Wastes and Multi-Source
Leachate (F039). Volume A:  Wastewater Forms of Organic U and P Wastes and
Multi-Source Leachate (F039) For Which There Are Concentration-Based Treatment
Standards (Reference 20).
                                      5-3

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5.4       Available Treatment Technologies

          The best technology for treatment of organic constituents in K017
nonwastewaters,  incineration, is considered to be commercially available.
Furthermore, the Agency has determined that this technology will provide
substantial treatment of F024, and therefore of K017 also.  Consequently, this
technology is considered to be available for treatment of K017 nonwastewaters
and has been determined to be BOAT.

          The best technologies for treatment of organic constituents in K017
wastewaters are also considered to be commercially available.  Furthermore,
the Agency has determined that these technologies will provide substantial
treatment of the constituents of concern in the tested wastes, and therefore
of K017 also.  Consequently, these technologies are considered to be available
for treatment of K017 wastewaters and have been determined to be BOAT.

          The identification of these technologies as BOAT for K017 does not
preclude a facility from utilizing recycle or reuse operations in accordance
with 40 CFR Part 261.  Also, since concentration-based standards are being
set, the BOAT technologies do not preclude the use of other treatment
technologies that can achieve the treatment standards as long as the other
treatment technologies do not constitute impermissible dilution or land
disposal.
                                      5-4

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6.0       SELECTION OF REGULATED CONSTITUENTS

          The Agency has developed a list of hazardous constituents (the BDAT
Constituent List, presented in EPA's Methodology for Developing BDAT Treatment
Standards (Reference 8)) from which constituents are selected for regulation.
EPA may revise this list as additional data and information became available.
The list is divided into the following categories:   volatile organics,
semivolatile organics, metals, inorganics other than metals, organochlorine
pesticides, phenoxyacetic acid herbicides, organophosphorus insecticides,
polychlorinated biphenyls (PCBs), and dioxins and furans.  This section
presents EPA's methodology and rationale for selection of regulated
constituents in K017 nonwastewaters and wastewaters.  (All tables are
presented at the end of this section.)

          Generally, constituents selected for regulation must satisfy the
following criteria:

          1.   The  constituent must be on the BDAT List of constituents.
               Presence on the BDAT List means that EPA-approved methods
               exist  for analysis of the constituent  in treated waste
               matrices.
          2.   The  constituent must be present in. or be suspected of being
               present  in. the untreated waste.  For example, analytical
               difficulties may  prevent a constituent from being identified
               in  the untreated  waste, but its identification in a treatment
               residual may lead the Agency  to conclude that it is present in
               the  untreated waste.

          From a group of constituents that are eligible for regulation
because they meet  the above criteria, EPA may select a subset of constituents
that represents the broader group.  For example, from a group of constituents
that react similarly  to treatment, the Agency may select for regulation those
constituents that  (1) are the most difficult to treat, based on waste
characteristics affecting treatment performance; (2) are representative of
other constituents  in the waste, based on structural similarities; or (3) are
present in the untreated waste in the highest concentrations.  Selecting a
subset of constituents  for regulation is done to facilitate implementation of
the compliance and  enforcement program.
                                      6-1

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          The Agency initially considered all constituents on the BDAT List
for regulation.  Table 6-1 summarizes available waste characterization data
for the BDAT List constituents in K017 (as derived from Table 2-2).  Ranges of
concentrations for constituents detected in the waste are shown in the table.
Constituents for which no analysis was performed are identified by "NA" (not
analyzed).

          Generally, a BDAT List constituent is deleted from further
consideration for regulation if:  (1) the constituent was not analyzed for in
the untreated waste; (2) detection limits or analytical results were not
obtained for the constituent due to analytical problems; or (3) available
treatment performance data for the constituent did not show effective
treatment by BDAT.

6.1       BDAT List Constituents Not Selected For Regulation

6.1.1     BDAT List Constituents Not Analyzed For in the Untreated Waste

          Some constituents on the BDAT List were deleted from further
consideration for regulation because these constituents were not analyzed for
in the untreated waste (labeled "NA" in Table 6-1).  These constituents were
not analyzed for because it is extremely unlikely that they would be present
in the untreated waste, based on the processes generating K017.  These
constituent types include metals, inorganics, organochlorine pesticides,
phenoxyacetic acid herbicides, organophosphorus insecticides, polychlorinated
biphenyls (PCBs), and dioxins and furans.

6.1.2     BDAT List Constituents For Which Detection Limits or Analytical
          Results Were Not Obtained Due to Analytical Problems

          There were no BDAT List constituents that were deleted from further
consideration for regulation based on this consideration.
                                      6-2

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6.1.3     BOAT List Constituents For Which Available Treatment Performance
          Data Did Not Show Effective Treatment by BOAT

          There were no BOAT List constituents that were deleted from further
consideration for regulation based on this consideration.

6.2       BOAT List Constituents Selected For Regulation

          All of the BOAT List organic constituents that were further consid-
ered for regulation in K017 nonwastewaters and wastewaters were selected for
regulation.  Table 6-2 presents the three BOAT List constituents selected for
regulation in K017 nonwastewaters and wastewaters.

6.3       Non-BDAT List Constituents

          Of the six constituents of concern identified in the K017 character-
ization data, three are BOAT List constituents and three are non-BDAT List
constituents.  The three non-BDAT List constituents of concern are bis(2-
chloromethyl)ether, epichlorohydrin, and dichloropropanol.  While these non-
BDAT List constituents are present in K017 at high concentrations, there are
currently no EPA-approved methods for analysis of these constituents in the
K017 matrix.  Therefore, these constituents could not be considered for
regulation.
                                      6-3

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                                   Table  6-1

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED KOI7
                                             Concentration in Untreated Waste
BDAT List Constituent

Volatiles

222.  Acetone
  1.  Acetonitrile
  2.  Acrolein
  3.  Acrylonitrile
  4.  Benzene
  5.  Bromodichloromethane
  6.  Bromomethane
223.  n-Butyl alcohol
  7.  Carbon tetrachloride
  8.  Carbon disulfide
  9.  Chlorobenzene
 10.  2-Chloro-1,3-butadiene
 11.  Chlorodibromomethane
 12.  Chloroethane
 13.  2-Chloroethyl vinyl ether
 14.  Chloroform
 15.  Chloromethane
 16.  3-Chloropropene
 17.  l,2-Dibromo-3-chloropropane
 18.  1,2-Dibromoethane
 19.  Dibromomethane
 20.  trans-l,4-Dichloro-2-butene
 21.  Dichlorodifluoromethane
 22.  1,1-Dichloroethane
 23.  1,2-Dichloroethane
 24.  1,1-Dichloroethylene
 25.  trans-l,2-Dichloroethene
 26.  1,2-Dichloropropane
 27.  trans-l,3-Dichloropropene
 28.  cis-l,3-Dichloropropene
 29.  1,4-Dioxane
224.  2-Ethoxyethanol
225.  Ethyl acetate
226.  Ethyl benzene
 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
0.1-1
 NA
 NA
 NA
 NA
 NA
 NA
NA - Not analyzed.
                                      6-4

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                             Table  6-1  (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
                                             Concentration in Untreated Waste
BOAT List Constituent                        	(%)	
                   I

Volatiles (Continued)

 30.  Ethyl cyanide                                        NA
227.  Ethyl ether                                          NA
 31.  Ethyl methacrylate                                   NA
214.  Ethylene oxide                                       NA
 32.  lodomethane                                          NA
 33.  Isobutyl alcohol                                     NA
 37.  Methacrylonitrile                                    NA
228.  Methanol                                             NA
 34.  Methyl ethyl!ketone                                  NA
229.  Methyl isobutyl ketone                               NA
 35.  Methyl methacrylate                                  NA
 38.  Methylene chloride                                   NA
230.  2-Nitropropahe                         .              NA
 39.  Pyridine                                             NA
 40.  1,1,1,2-Tetrachloroethane                            NA
 41.  1,1,2,2-Tetrachloroethane                            NA
 42.  Tetrachloroethene                                    NA
 43.  Toluene                                              NA
 44.  Tribromomethane                                      NA
 45.  1,1,1-Trichloroethane                                NA
 46.  1,1,2-Trichloroethane                                NA
 47.  Trichloroethene                                      NA
 48.  Trichloromonofluoromethane                           NA
 49.  1,2,3-Trichloropropane                            <0.01-70
231.  l,l,2-Trichl6ro-l,2,2-trifluoroethane                NA
 50.  Vinyl chloride                                       NA
215.  1.2-Xylene                                           NA
216.  1,3-Xylene                                           NA
217.  1,4-Xylene                                           NA
NA - Not analyzed.
                                      6-5

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                            Table 6-1  (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
                                             Concentration in Untreated Waste
BOAT List Constituent

Semivolatiles

 51.  Acenaphthalene
 52.  Acenaphthene
 53.  Acetophenone
 54.  2-Acetylaminofluorene
 55.  4-Aminobiphenyl
 56.  Aniline
 57.  Anthracene
 58.  Aramite
 59.  Benz(a)anthracene
218.  Benzal chloride
 60.  Benzenethiol
 62.  Benzo(a)pyrene
 63.  Benzo(b)fluoranthene
 64.  Benzo(ghi)perylene
 65.  Benzo(k)fluoranthene
 66.  p-Benzoquinone
 67..  Bis(2-chloroethoxy)methane
 68.  Bis(2-chloroethyl)ether
 69.  Bis(2-chloroisopropyl)ether
 70.  Bis(2-ethylhexyl)phthalate
 71.  4-Bromophenyl phenyl ether
 72.  Butyl benzyl phthalate
 73.  2-sec-Butyl-4,6-dinitrophenol
 74.  p-Chloroaniline
 75.  Chlorobenzilate
 76.  p-Chloro-m-cresol
 77.  2 -Chloronaphthalene
 78.  2-Chlorophenol
 79.  3-Chloropropionitrile
 80.  Chrysene
 81.  ortho-Cresol
 82.  para-Cresol
232.  Cyclohexanone
 83.  Dibenz(a,h)anthracene
 84.  Dibenzo(a,e)pyrene
 85.  Dibenzo(a,i)pyrene

NA  - Not analyzed.
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
14
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                      6-6

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Table 6-1 (Continued)

STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
\

BOAT
Concentration
List Constituent
/
in Untreated Waste
(%)
Semivolatiles (Continued)
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
219.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.
m-Dichlorobenzene
o - Dichlorobenzene
p- Dichlorobenzene
3,3' -Dichlorbbenzidine
2,4-Dichlorophenol
2 , 6 - Dichlorophenol
Diethyl phthalate
3 , 3-Dimethoxybenzidine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1,4-Dinitrobenzene
4 , 6-Dinitro-o-cresol
2 , 4 - D ini tropheno 1
2,4-Dinitrotpluene
2 , 6 -Dinitro toluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
Diphenylnitrbsamine
1,2- dipheny Ihydraz ine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroe thane
Hexachlorophene
Hexachloropropene
Indeno(l , 2 , 3-cd)pyrene
Isosafrole
Methapyrilene
3 -Methylcholanthrene
4,4' -Methylenebis (2-chloroaniline)
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
NA
NA
NA
NA
NA
NA
NA
NA
NA - Not analyzed.
                                     6-7

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                            Table  6-1  (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
                                             Concentration in Untreated Waste
BOAT List Constituent                        	(%)	

Semivolatiles (Continued)

 36.  Methyl methanesulfonate                              NA
121.  Naphthalene                                          NA
122.  1,4-Naphthoquinone                                   NA
123.  1-Naphthylamine                                      NA
124.  2-Naphthylamine                                      NA
125.  p-Nitroaniline                                       NA
126.  Nitrobenzene                                         NA
127.  4-Nitrophenol                                        NA
128.  N-Nitrosodi-n-butylamine                             NA
129.  N-Nitrosodiethylamine                                NA
130.  N-Nitrosodimethylamine                               NA
131.  N-Nitrosomethylethylamine                            NA
132.  N-Nitrosomorpholine                                  NA
133.  N-Nitrosopiperidine                                  NA
134.  N-Nitrosopyrrolidine                                 NA
135.  5-Nitro-o-toluidine                                  NA
136.  Pentachlorobenzene                                   NA
137.  Pentachloroethane                                    NA
138.  Pentachloronitrobenzene                              NA
139.  Pentachlorophenol                                    NA
141.  Phenanthrene                                         NA
142.  Phenol                                               NA
220.  Phthalic anhydride                                   NA
143.  2-Picoline                                           NA
144.  Pronamide                                            NA
145.  Pyrene                                               NA
146.  Resorcinol                                           NA
147.  Safrole                                              NA
148.  1,2,4,5-Tetrachlorobenzene                           NA
149.  2,3,4,6-Tetrachlorophenol                            NA
150.  1,2,4-Trichlorobenzene                               NA
151.  2,4,5-Trichlorophenol                                NA
152.  2,4,6-Trichlorophenol                                NA
153.  Tris(2,3-dibromopropyl)phosphate                     NA


NA - Not analyzed.
                                      6-8

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                             Table  6-1  (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
                                             Concentration in Untreated Waste
BOAT List Constituent
Metals

154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel      :
Selenium
Silver
Thallium
Vanadium
Zinc
Inorganics        \

169.   Cyanide
170.   Fluoride
171.   Sulfide

Organochlorine Pesticides

172.   Aldrin
173.   alpha-BHC   j
174.   beta-BHC
175.   delta-BHC
176.   gamma-BHC
177.   Chlordane   !
178.   ODD
179.   DDE
180.   DDT
181.   Dieldrin
182.   Endosulfan  I
183.   Endosulfan  II

NA -  Not analyzed.
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
                                                     NA
                                                     NA
                                                     NA
                                                     NA
                                      6-9

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                             Table  6-1  (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED KOI7
                                             Concentration in Untreated Waste
BOAT List Constituent

Organochlorine Pesticides (Continued)

184.   Endrin
185.   Endrin aldehyde
186.   Heptachlor
      Heptachlor epoxide
      Isodrin
      Kepone
      Methoxychlor
      Toxaphene
187
188
189
190
191
Phenoxvacetic Acid Herbicides

192.  2,4-Dichlorophenoxyacetic acid
193.  Silvex
194.  2,4,5-T

Organophosphorus Insecticides

195.  Disulfoton
196.  Famphur
197.  Methyl parathion
198.  Parathion
199.  Phorate

Polvchlorinated Biphenvls (PCBs)

200.  Aroclor 1016
20l'.  Aroclor 1221
202.  Aroclor 1232
203.  Aroclor 1242
204.  Aroclor 1248
205.  Aroclor 1254
206.  Aroclor 1260
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 - Not analyzed.
                                     6-10

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                             Table 6-1 (Continued)

              STATUS OF BOAT LIST CONSTITUENTS IN UNTREATED K017
                                             Concentration in Untreated Waste
BOAT List Constituent                        	(%)  	
Dioxins and Furans
207.  Hexachlorodibenzo-p-dioxins
208.  Hexachlorodibenzofuran
NA - Not analyzed.
                                     6-11
NA
«_ W W •   A AW>^Wb»^B« ** ifcWT ^ V%*«, V^ kb««%' A. IHkAi b*bk                                 li
209.   Pentachlorodibenzo-p-dioxins                          NA
210.   Pentachlorodibenzofuran                               NA
211.   Tetrachlorodibenzo-p-dioxins                          NA
212.   Tetrachlorodibenzofuran                               NA
213.   2,3,7,8-Tetrachlorodibenzo-p-dioxin                   NA

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                                  Table  6-2

            BOAT LIST CONSTITUENTS SELECTED FOR REGULATION IN KOI7
                        NONWASTEWATERS AND WASTEWATERS
Nonwastevaters

26.  1,2-Dichloropropane
49.  1,2,3-Trichloropropane
68.  Bls(2-chloroethyl)ether
Wastewaters

26.  1,2-Dichloropropane
49.  1,2,3-Trichloropropane
68.  Bis(2-chloroethyl)ether
                                     6-12

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7.0       CALCULATION OF BOAT TREATMENT STANDARDS

          The Agency bases numerical treatment standards for regulated con-
stituents on the performance of well-designed and well-operated BOAT treatment
systems.  These standards must account for analytical limitations in available
treatment performance data, and the data must be adjusted for variabilities
related to treatment, sampling, and analytical techniques and procedures.
This section discusses the calculation of treatment standards for K017
nonwastewaters and wastewaters for the constituents selected for regulation
using the available treatment performance data from the BOAT treatment
technology.

          As noted in Section 5.0, before treatment standards are calculated,
the treatment performance data are corrected to account for analytical
interferences associated with the chemical matrices of the samples.  After
treatment performance data are corrected for accuracy, the arithmetic average
of the corrected data is calculated for each regulated constituent.  In cases
where the constituent is not detected above its detection limit, the detection
limit is used to calculate the average constituent concentration in the
treated waste.  The next step in calculating treatment standards is to
determine the variability factor (VF) for each regulated constituent.  The
variability factor accounts for the variability inherent in treatment system
performance, treatment residual collection, and treatment sample analysis.
(For more information on calculation of variability factors, see EPA's
Methodology for Developing BOAT Treatment Standards (Reference 8).) Finally,
the treatment standard is calculated for each regulated constituent by
multiplying the ayerage of the corrected treatment performance values by  the
variability factor for the constituent.

          BDAT treatment standards for constituents being regulated in K017
nonwastewaters were calculated as shown in Section 6.0 of EPA's Final Best
Demonstrated Available Technology (BDAT) Background Document For U and P
Wastes and Multi-Source Leachate (F039). Volume C:  Nonwastewater Forms of
Organic U and P Wastes and Multi-Source Leachate  (F039) For Which There Are
Concentration-Based Treatment Standards (Reference 19).
                                      7-1

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          BDAT treatment standards for constituents being regulated in K017
wastewaters were calculated as shown in Section 6.0 of EPA's Final Best
Demonstrated Available Technology (BDAT) Background Document For U and P
Wastes and Multi-Source Leachate (F039). Volume A:  Wastewater Forms of
Organic U and P Wastes and Multi-Source Leachate (F039) For Which There Are
Concentration-Based Treatment Standards (Reference 20).

          Treatment standards for the regulated constituents in nonwastewater
and wastewater forms of K017 are presented in Table 1-1.
                                      7-2

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8.0       ACKNOWLEDGEMENTS
                      .
          This background document was prepared for the U.S.  Environmental
Protection Agency, Office of Solid Waste,  by Radian Corporation,  under
Contract No. 68-W9-0072.  This document was prepared under the direction of
Richard Kinch, Acting Chief, Waste Treatment Branch; Larry Rosengrant, Section
Head, Treatment Technology Section; Jerry Vorbach,  Project Officer;  and Elaine
Eby, Project Manager.  Steve Silverman served as EPA legal advisor.

          The following personnel from Radian Corporation were involved in
preparing this document:  John Williams, Program Manager; and Mary Willett,
Project Director.  .
                                      8-1

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9.0       REFERENCES
 1.  U.S. EPA.  1981.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Identification and Listing of Hazardous Waste Under RCRA. Sub-
     title C. Section 3001. Background Document.  Washington, D.C.:  U.S.
     Environmental Protection Agency.

 2.  Hydroscience.  1978.  Trip Report Emission Control Options for the
     Synthetic Organic Chemicals Manufacturing Industry.  Trip report for the
     allyl chloride-epichlorohydrin-glycerin process at Dow Chemical Company.
     Freeport. Texas.  Washington, D.C.:  U.S. Environmental Protection
     Agency.       ;

 3.  U.S. EPA.  1981.  U.S. Environmental Protection Agency, Office of Water
     Regulations and Standards.  Contractors Engineering Analysis of Organic
     Chemicals and Plastics/Synthetic Fibers Industries. Appendix S, Chapter
     41.  Washington, D.C.:  U.S. Environmental Protection Agency.

 4.  SRI International.  1988.  1988 Directory of Chemical Producers-United
     States of America.  Menlo Park, CA:  SRI International.

 5.  U.S. EPA.  1980.  U.S. Environmental Protection Agency, Office of Air
     Quality Planning and Standards.  Glycerin and its intermediates epichlo-
     rohvdrin. acrblein and allyl chloride.  Washington, D.C.:  U.S. Environ-
     mental Protection Agency.

 6.  U.S. EPA.  U.S. Environmental Protection Agency, Office of Solid Waste.
     Listing Background Document  - Epichlorohvdrin Production.  Washington,
     D.C.:  U.S. Environmental Protection Agency.

 7.  U.S. EPA.  1989.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Final Best Demonstrated Available Technology (BOAT) Background
     Document for Wastes from the Production of Chlorinated Aliphatic Hydro-
     carbons - F024.  Washington, D.C.:  U.S. Environmental Protection
     Agency.

 8.  U.S. EPA.  1989.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Methodology for Developing BOAT Treatment Standards.  June,
     1989.  Washington, D.C.:  U.S. Environmental Protection Agency.

 9.  U.S. EPA.  1989.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Treatment Technology Background Document.  June, 1989.  Washing-
     ton, D.C.:  U.S. Environmental Protection Agency.

10.  American Public Health Association, American Water Works Association,
     and Water Pollution Control  Federation.  1985.  Standard Methods for  the
     Examination of Water and Wastewater.  Sixteenth Edition.  Washington,
     D.C.
                                      9-1

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11.   U.S. EPA.  1988.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  F024 Characterization Report for DuPont Chemical Company.
     LaPlace. LA.  Washington, D.C.:  U.S. Environmental Protection Agency.

12.   U.S. EPA.  1988.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  F024 Characterization Report for Shell Chemical Company. Norco.
     LA.  Washington, D.C.:  U.S. Environmental Protection Agency.

13.   U.S. EPA.  1988.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  F024 Characterization Report for Vista Chemical Company. Lake
     Charles. LA.  Washington, D.C.:  U.S. Environmental Protection Agency.

14.   U.S. EPA.  1988.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  F024 Characterization Report for Vulcan Chemicals. Wichita.  KS.
     Washington, D.C.:  U.S. Environmental Protection Agency.

15.   U.S. EPA.  1988.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Onsite Engineering Report of Treatment Technology Performance
     and Operation for Incineration at ENSCO. El Dorado. AR.  Washington,
     D.C.:  U.S. Environmental Protection Agency.

16.   Weast, R.C., editor.  1984.  CRC Handbook of Chemistry and Physics.  65th
     Edition.  Boca Raton, FL:  CRC Press, Inc.

17.   Windholz, M., editor.  1983.  The Merck Index.  10th Edition.  Rahway,
     NJ:  Merck and Co.

18.   U.S. EPA.  1985.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Characterization of Waste Streams Listed in 40 CFR Section 261
     Waste Profiles.  Volume I.  Washington, D.C.:  U.S. Environmental
     Protection Agency.

19.   U.S.EPA. 1990.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Final Best Demonstrated Available Technology (BOAT) Background
     Document for U and P Wastes and Multi-Source Leachate  (F039). Volume C:
     Nonwastewater Forms of Organic U and P Wastes and Multi-Source Leachate
     (F039) For Which There Are Concentration-Based Treatment Standards.
     Washington, D.C.:  U.S. Environmental Protection Agency.

20.   U.S.EPA. 1990.  U.S. Environmental Protection Agency, Office of Solid
     Waste.  Final Best Demonstrated Available Technology (BOAT) Background
     Document for U and P Wastes and Multi-Source Leachate  (F039). Volume A:
     Wastewater Forms of OrEanic U  and P Wastes and Multi-Source Leachate
     (F039) For Which There Are Concentration-Based Treatment Standards.
     Washington, D.C.:  U.S. Environmental Protection Agency.
                                      9-2

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                     APPENDIX A




WASTE1CHARACTERISTICS AFFECTING TREATMENT PERFORMANCE
                         A-l

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                                   Table A-l

              BOILING POINTS FOR CONSTITUENTS OF CONCERN IN K017
BOAT List Constituent

26.  1,2-Dichloropropane
49.  1,2,3-Trichloropropane
68.  Bis(2-chloroethyl)ether
     Bis(2-chloromethyl)ether
     Epichlorohydrin
     Dichloroporanol
 Boiling
Point (°C)

    96.4
   156.8
   178
   104
   -16.5
    28
Reference No,

      16
      16
      17
      16
      17
      17
Source:  Merck Index (Reference 17).
                                      A-2

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                                  Table A-2

         BOND  DISSOCIATION  ENERGIES  FOR CONSITUENTS OF CONCERN  IN K017
                                          Bond Dissociation Energy
BOAT List Constituent                     	(kcal/mole)	

26.  1,2-Dichloropropane                              930
49.  1,2,3-Trichloropropane                           910
68.  Bis(2-chloroethyl)ether                        1,290
     Bis(2-chloromethyl)ether                         720
     Epichlorohydrin                                  910
     Dichloropropanol                               1,025
Source:  CRC Handbook of Chemistry and Physics (Reference 16).
                                      A-3

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             APPENDIX  B




WASTEWATER TREATMENT PERFORMANCE DATA
                 B-l

-------
            1.2-Dichloroprooane  (U083).   The  data available for 1,2-
  dichloropropane were compiled  from  the  WERL database and the EPA WAO test.
  These data are presented  in Table 4-23.   Technologies for which data are
  available include AS, AirS, ozonation  (ChOx(Oz)),  GAG,  and WOX.  The treatment
  performance data represent bench-,  pilot-,  and full-scale studies.  The
  resulting effluent concentrations ranged from 0.500 ppb to 1,800 ppb.

            BOAT for 1,2-dichloropropane  is being promulgated as proposed and  is
  identified as activated sludge biological treatment (AS).  Activated sludge
  was selected as BOAT because it  represents  full-scale data with various high
  influent ranges and substantial  treatment removals.  The activated sludge data
  were used in preference to the EPA  WAO  test data due to the lower effluent
  values achievable by activated sludge  treatment as well as the fact that it
  represents full-scale data over  the WAO pilot-scale data.  The BOAT treatment
  standard for 1,2-dichloropropane was calculated using an effluent
  concentration of 148.4 ppb (which represents an average of the AS effluent
  concentrations presented  for full-scale treatment) and the appropriate
  variability factor and accuracy  correction  factor.  The calculation of the
  resulting BOAT treatment  standard for  1,2-dichloropropane (0.85 ppm) is
  described in Section 6.0  and is  shown  in Table 6-10.
                                   TABLE 4-23
                          WASTEWATER TREATMENT PERFORMANCE DATA
                               FOR 1,2-DICHLOROPROPANB

TECHNOLOGY


* AS
AS
AS
* AS
* .AS
* AS
AS
* AS
AirS
AirS
ChOx (Oz)
ChOx [Oz
GAC
Wx

TECHNOLOGY
SIZE

Pull
Bench
Pilot
Ml
w
Pilot
full
Pilot
PUot
Pilot
Pilot
Pilot
Pilot

FACILITY


6B
202D
241B
IB
$
206B
6B
222B
1362E
331D
331D
331D
Zinpro
DETECTION RANGE
LIMIT INFLCENT
(ppb) CONCENTRATION
(ppb)
100-1000
100000-1000000
100-1000
1000-10000
1000-10000
1000-10000
100-1000
100-1000
0-100
100-1000
0-100
0-100
0-100
150 550000-630000
NO. OF
DATA
POINTS

15

5
1
3
20
24
1
3


3
AVERAGE
EFFLDENT
CONCENTRATION
(ppb)
490.000
1800.000
61.000
1.000
180.000
60.000
6.000
11.000
0.500
2.700
3.000
4.800
1.000
1607.000

RECOVERY REMOVAL
(*) (*)

37
99.01
76
99.96
98.2
96.7
98.1
98.2
75
99
33
21
84


REFERENCE


ViERL *
XERL
XERL
XERL *
XERL *
XERL *

XERL *
XERL
XERL
XERL

XERL
XAO
Data used in developing proposed standard.
                                         B-2

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          1.2.3-Trichloroorooane.   No wastewater treatment performance data
were available for 1,2,3-trichloropropane from any of the examined sources.
Treatment performance data were therefore transferred to this constituent from
a constituent judged to be similar in elemental composition and functional
groups within the structure of the chemical.  For constituents represented by
a U or P code, this means that constituents included in the same waste
treatability group (see Appendix B) were candidates for transfer of data.
1,2,3-Trichloropropane is similar in structure to those constituents in
treatability group II.A.2.b.(3) and the constituent used to transfer treatment
performance data from was 1,2-dichloropropane.  The treatment performance data
for 1,2-dichloropropane is presented in Table 4-23.  Using a transfer from
this constituent results in a BOAT for 1,2,3-trichloropropane of activated
sludge biological treatment and a BOAT treatment standard of 0.85 ppm as
described in Section 6.0 and shown in Table 6-10.
                                     B-3

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            Bls(2-chloroethvl^ether (U025).   The data available for bis(2-
  chloroethyl)ether were compiled from the NPDES and WERL databases and  are
  presented in Table 4-63.  Technologies for which data are available  include
  AL, AS, BT, CAC, ChOx, and TF.   The treatment performance data represent
  bench-, pilot-, and full-scale  studies.   The resulting effluent concentrations
  ranged from 1 ppb to 430 ppb.

            BOAT  for bis(2-chloroethyl)ether is being promulgated as proposed
  and is identified as activated  sludge biological treatment (AS).  Activated
  sludge was selected as BOAT because the data represent full-scale treatment
  performance with a high influent concentration and high removal efficiency.
  The BOAT treatment standard for bis(2-chloroethyl)ether was calculated using
  the effluent concentration of 6 ppb and the appropriate variability  factor and
  accuracy correction factor.   The calculation of the resulting BOAT treatment
  standard for bis(2-chloroethyl)ether (0.033 ppm) is described in Section  6.0  .
  and is shown in Table 6-10.
                                     TABLE 4-63
                            WASTEWATER TREATMENT PERFORMANCE DATA
                               FOR BIS(2-CHLOROBTHYL)ETHE5
TECHNOLOGY
AL
AL
AS
AS
AS
AS
* AS
BT
BT
BT
BT
BT
BT
CAC
ChOx
TF
TF
DETECTION RANGE
TECHNOLOGY FACILITY LIMIT INFLCENT
SHE (ppb) CONCENTRATION
V (ppb)
LA0065501
PA0012777
MY0107174
KI0000868
LA0066214
Pilot 203A
Pilot 203A
Full IB
Pilot 240A
Full 6B
Pilot 203A
Fu
Fu
Fu
Fu
Fu
Fu
Fu
1 975B
KY0002119
LTO038245
PA0026247
PA0026689
KI0029173
1 H0029173
Pilot 203A
Bench 975B
Pilot 203A
Pilot 240A
100-1000
100-1000
100-1000
0-100
1000-10000
100-1000
1000-10000






100-1000
1000-10000
100-1000
0-100
NO. OF AVERAGE
DATA EFFLUENT RECOVERY REMOVAL
POINTS CONCENTRATION (1) (!)
(ppb)
6
38
8
8
15
11
11
11
9
11

13
38
25
2
15
15
11
11
8
10.000
3.014
25.875
2.750
10.000
102.000
78.000
13.000
29.000
430.000
30.000
6.000
12.080
12.492
10.880
2.500
1.000
1.000
114.000
6.000
132.000
65.000
29
46
98.3
67
73
79
99.87






20
99.74
8
32
REFERENCE
HPDES
HPDES
HPDES
HPDES
HPDES
PL
'mi
mi
mi
'mi *
HPDES
HPDES
HPDES
HPDES
HPDES
HPDES
#ERL
*ERL
"XERL
VfERL
Data used in developing proposed standard.
                                        B-4

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