FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT
FOR
DISTILLATION BOTTOMS FROM THE PRODUCTION OF NITROBENZENE
BY THE NITRATION OF BENZENE
K025
Richard Kinch
Acting Chief, Waste Treatment Branch
Jose Labiosa
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
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 2-1
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 3-5
4.0 TREATMENT PERFORMANCE DATA 4-1
4.1 Nonwastewaters 4-1
4.2 Wastewaters 4-2
5.0 IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) 5-1
5.1 Review of Treatment Performance Data 5-1
5.2 Available Treatment Technologies 5-2
5.3 BOAT for K025 5-2
6.0 DETERMINATION OF BOAT TREATMENT STANDARDS 6-1
6.1 Nonwastewaters 6-1
6.2 Wastewaters 6-2
7.0 ACKNOWLEDGEMENTS 7-1
8.0 REFERENCES 8-1
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LIST OF TABLES
Page
1-1 BOAT TREATMENT STANDARDS FOR K025 1-4
2-1 K025 CHARACTERIZATION DATA 2-4
4-1 WASTES TESTED BY INCINERATION AND SAMPLED BY EPA 4-4
ii
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LIST OF FIGURES
Page
2-1 FLOW DIAGRAM FOR THE PRODUCTION OF NITROBENZENE BY THE
NITRATION OF BENZENE 2-3
iii
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1.0 INTRODUCTION
. The U.S. Environmental Protection Agency (EPA or Agency) is estab-
lishing best demonstrated available technology (BOAT) treatment standards for
the listed hazardous waste identified in Title 40, Code of Federal Regula-
tions. Section 261.32 (40 CFR 261.32) as K025, distillation bottoms from the
production of nitrobenzene by the nitration of benzene. These BOAT 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. BOAT treat-
ment standards will be effective no later than May 8, 1990, and on or after
the effective date, compliance with these BOAT treatment standards will be a
prerequisite under 40 CFR Part 268 for placement of the waste in land disposal
units.
This background document provides the Agency's rationale and techni-
cal support for developing treatment standards for K025. The document also
provides waste characterization data that serve as a basis for determining
whether a variance from the treatment standard may be warranted for a par-
ticular type of K025 that is more difficult to treat than the wastes on which
the K025 treatment standards are based.
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 BOAT Treatment Standards (Reference 1).
Under 40 CFR 261.32, wastes identified as K025 are listed as distil-
lation bottoms from the production of nitrobenzene by the nitration of ben-
zene. The four-digit Standard Industrial Classification (SIC) code associated
with the production of nitrobenzene is 2865 (Industrial Organic Chemicals:
cyclic organic crudes and intermediates, and organic dyes and pigments). The
Agency estimates that there is one domestic facility that may generate K025.
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The Agency is establishing treatment standards for nonwastewater and
wastewater forms of K025. To determine the applicability of the treatment
standards, wastewaters are defined as wastes containing less than 1% (weight
basis) total suspended solids1 (TSS) and less than 4% (weight basis) total
organic carbon (TOC). Wastes not meeting this definition are classified as
nonwastewaters and must comply with nonwastewater treatment standards.
The Agency is revising the "No Land Disposal Based on No Generation"
treatment standard that was promulgated for nonwastewater forms of K025, and
is establishing treatment standards for wastewater forms of K025, which have
been subject to the "soft hammer" provisions of Section 3004(g)(6) of RCRA.
The "No Land Disposal" standard for K025 nonwastewaters was based on the
premise that K025 is no longer generated. The Agency believes that this
standard should be revised for several reasons: (1) a facility intending to
manufacture nitrobenzene in the future by the nitration of benzene, and
generating distillation bottoms as a result, would be forced to apply for a
variance from the treatment standard (40 CFR 268.44); (2) a facility disposing
of K025 from past nitrobenzene manufacturing operations as part of a correc-
tive action would also be forced to apply for a variance from the treatment
standard; and (3) a facility changing its treatment process from one that
originally did not generate treatment residuals to one that may generate
residuals would be forced to apply for a variance from the treatment standard.
EPA is establishing a method of treatment as the treatment standard
for nonwastewater and wastewater forms of K025. The Agency is establishing
this treatment standard because it is uncertain as to what constituents are
present in K025, due to insufficient characterization data for K025. This
uncertainty precludes the selection of appropriate BOAT List constituents for
regulation, as explained in Section 6.0 of this document. The.treatment
1The 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 2).
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standards for nonwastewater and wastewater forms of K025 are shown in Table
1-1-
This background document presents waste-specific information on the
number and locations of facilities that may be affected by the land disposal
restrictions for K025, the processes generating this waste, the waste charac-
terization data, the technologies used to treat the waste (or similar wastes,
if any), and the treatment performance data which support the establishment of
treatment standards (Sections 2.0 - 4.0). This document also explains how EPA
determined BOAT and treatment standards for K025 (Sections 5.0 - 6.0).
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Table 1-1
BOAT TREATMENT STANDARDS FOR K025
NONWASTEWATERS
INCINERATION1 AS A METHOD OF TREATMENT
WASTEWATERS
INCINERATION1 AS A METHOD OF TREATMENT
OR
LIQUID-LIQUID EXTRACTION FOLLOWED
BY STEAM STRIPPING FOLLOWED BY INCINERATION
OF SPENT CARBON AS A METHOD OF TREATMENT
'Incineration must be conducted in accordance with the technical requirements
of 40 CFR Part 264 or Part 265 Support 0.
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2.0 INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
This section describes the industries that may be affected by the
land disposal restrictions for K025, the processes generating the waste, and
the available waste characterization data.
2.1 Industry Affected and Process Description
K025 is generated as distillation bottoms from the production of
nitrobenzene by the nitration of benzene. The primary use of nitrobenzene is
in the manufacture of aniline dyes. Nitrobenzene is also used as a solvent in
the manufacture of pharraaceuticals. The Agency has identified one potential
generator of K025: Rubicon, Inc., located in Geismar, Louisiana in EPA
Region VI (Reference 4).
A flow diagram illustrating a typical nitrobenzene production
process is presented in Figure 2-1. Nitrobenzene is produced by the direct
nitration of benzene using a sulfuric acid-nitric acid mixture. After a two-
to four-hour reaction residence time, the mixture is sent to a decanter and is
allowed to settle. The mixed acids are recovered and reused. The crude
nitrobenzene taken from the top of the decanter can be used directly for
aniline production or can be sent on for further refinement. For refinement,
the crude product is sent to a washer, where it is neutralized with a dilute
sodium carbonate solution and then distilled. Bottoms from this final distil-
lation comprise the listed waste K025.
2.2 Waste Characterization
K025, as generated, meets the definition of a BOAT nonwastewater.
However, wastewater forms of K025 may be generated during the treatment,
handling, or storage of nonwastewater forms of K025.
As discussed above, one facility was identified as a potential
generator of K025. However, K025 is not currently generated at this facility.
Therefore, a sample of K025 for full characterization was unavailable.
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Previously collected K025 characterization data for constituents on the BOAT
list are presented in Table 2-1.
Available data sources (References 5 and 6) indicate the following
general composition for K025:
Constituent Concentration (%)
2,4-Dinitrotoluene 18.6
Nitrobenzenes 71.5
Nitrophenols 3.1
Other polymers containing nitrogen 3.7
Polycarboxylic acids 3 .1
Total: 100%
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KJ
I
U)
Sulfuric Acid
Nitric Acid
Mixture
Keactor
Benzene
To A
Prod
i
Crude
Nitrobenzene
^ Decanter
1
If
Mixed Acids
to
Recovery
and Reuse
^
niline
uction
Dilute
Sodium
Carbonate
Solution
Washing
Decanter
I
Wash Wate
to
Disposal
r
Dis
lal
Col
til-
tion
umn
K025
I
Nitrobenzene
Figure 2-1. Flow Diagram for the Production of Nitrobenzene
by the Nitration of Benzene
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Table 2-1
K025 CHARACTERIZATION DATA
Concentration in
BOAT List Constituent Untreated Waste (pom)
102. 2,4-Dlnitrotoluene 186,000
126. Nitrobenzene 404,000
127. 4-Nitrophenol 31,000
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3.0 APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
This section discusses the technologies that are applicable for
treatment of K025 nonwastewaters and wastewaters and determines which, if any,
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 a waste that is similar in terms of parameters that
affect treatment selection. (Detailed descriptions of technologies that are
applicable to listed hazardous wastes are provided in EPA's Treatment Technol-
ogy Background Document (Reference 7).) To be demonstrated, a technology must
be employed in full-scale operation for treatment of the waste in question or
a similar waste. Technologies available only at pilot- or bench-scale opera-
tions are not considered in identifying demonstrated technologies.
3.1 Applicable Treatment Technologies
The following subsections present applicable treatment technologies
for nonwastewater and wastewater forms of K025.
3.1.1 Nonwastewaters
Since nonwastewater forms of K025 consist primarily of organic
compounds (as shown in Section 2.0 of this document), applicable treatment
technologies include those that destroy or reduce the total amount of various
organic compounds in the waste. The Agency has identified the following
treatment technologies as potentially applicable for these wastes: (1)
incineration (fluidized-bed and rotary kiln); (2) solvent extraction followed
by incineration or recycle of the extract; and (3) critical fluid extraction
followed by recycle or incineration of the contaminated solvents. These
treatment technologies were identified based on engineering judgment and
current waste management practices for organic wastes.
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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 organic constituents. In a fluidized-bed incinera-
tor, 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, wastes are 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 com-
plete destruction of organic waste constituents. Other wastes may also be
injected into the afterburner.
Combustion gases from the fluidized-bed or kiln afterburner are then
fed to a scrubber system for cooling and removal of entrained particulates and
acid gases, if present. In general, two residuals are generated by these
incineration processes: ash and scrubber water.
Solvent Extraction. Solvent extraction (or liquid-liquid extrac-
tion) 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 residual and an extract. The extract may be recycled or may
be further 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 organic constituents from the wastes. After the
extraction step, the solvent (liquified gas at its critical state) is brought
to its normal condition in the gaseous state and generates a small volume of
extract that is concentrated in hazardous organic constituents. This technol-
ogy results in the generation of two treatment residuals: a treated waste
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residual and an extract. The extract may be recycled or may be further
treated by incineration.
3.1.2 Wastewaters
Since wastewater forms of K025 may contain organic constituents at
treatable concentrations, applicable technologies include those that destroy
or reduce the total amount of various organic compounds in the waste. The
Agency has identified the following treatment technologies as potentially
applicable for treatment of K025 wastewaters: (1) incineration; (2) steam
stripping; (3) biological treatment (including PACT" treatment); (4) carbon
adsorption; (5) solvent extraction; and (6) wet air oxidation.
Incineration. Incineration of wastewaters in a rotary kiln or
fluidized-bed is identical to that for nonwastewaters described previously in
this section. In addition, liquid injection incineration may also be applica-
ble to K025 wastewaters. In a liquid injection incinerator, liquid wastes are
atomized and injected into the incinerator. Combustion gases from the incin-
erator are then fed to a scrubber system for cooling and removal of entrained
particulates and acid gases, if present. In general, only wastes with low or
negligible ash contents are amenable to liquid injection incineration. There-
fore, this technology generally does not result in the generation of an ash
residual.
Steam Stripping. Steam stripping is a separation technology in
which organics are removed from the waste by volatilization through the
application of heat. This technology results in the formation of two treat-
ment residuals: a treated waste extract and a treated effluent. The treated
waste extract and the treated effluent may require further treatment by
incineration, and carbon adsorption or biological treatment, respectively.
Biological Treatment. Biological treatment is a destruction tech-
nology in which organic constituents in wastewaters are biodegraded. This
technology results in the formation of two treatment residuals: a treated
effluent and a waste biosludge. The treated effluent and the waste biosludge
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may require further treatment for metals by chemical precipitation and stabi-
lization, respectively.
PACTH treatment is the addition of powdered activated carbon to a
biological treatment process. This technology results in the formation of two
treatment residuals: a treated effluent and a waste biosludge. The treated
effluent and the waste biosludge may require further treatment for metals by
chemical precipitation and stabilization, respectively. In addition, the
waste biosludge may require further treatment by incineration.
Carbon Adsorption. Carbon adsorption is a separation technology in
which organic constituents in wastewaters are selectively adsorbed onto
activated carbon. This technology results in the formation of two treatment
residuals: a treated effluent and spent carbon. The treated effluent may
require further treatment for metals by chemical precipitation. The spent
carbon may require further treatment by incineration.
Solvent Extraction. Solvent extraction of wastewaters is identical
to that for nonwastewaters described previously in this subsection.
Wet Air Oxidation. Wet air oxidation is a destruction technology in
which organic constituents in wastes are oxidized and destroyed under pressure
at elevated temperatures in the presence of dissolved oxygen. This technology
is applicable for wastes comprised primarily of water and up to 10% total
organic concentration. Wet air oxidation results in the formation of one
treatment residual: treated effluent. The treated effluent may require
further treatment for organic constituents by carbon adsorption or PACT"
treatment, as described in this subsection. Emissions from wet air oxidation
may require further treatment by incineration.
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3.2 Demonstrated Treatment Technologies
The Agency is not aware of any facilities that treat K025 nonwaste-
waters and wastewaters. Therefore, the Agency is not aware of any technolo-
gies that are specifically demonstrated for treatment of K025. However,
incineration is demonstrated for nonwastewater and wastewater forms of similar
wastes, as discussed in Section 4.0 of this document. Additionally, liquid-
liquid extraction followed by steam stripping followed by activated carbon
adsorption is demonstrated for similar wastewaters. The Agency tested liquid-
liquid extraction followed by steam stripping followed by activated carbon
adsorption for similar wastes, as discussed in Section 4.0 of this document.
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4.0 TREATMENT PERFORMANCE DATA
This section presents the treatment performance data that were used
to support the establishment of treatment standards for nonwastewater and
wastewater forms of K025.
The Agency does not have treatment performance data for treatment of
K025 nonwastewaters or wastewaters. However, the Agency does have performance
data for similar wastes previously tested by incineration (rotary kiln or
fluidized-bed incineration) for nonwastewaters, and by liquid-liquid
extraction followed by steam stripping and activated carbon adsorption for
wastewaters. These technologies were identified as applicable and
demonstrated for treatment of these wastes, as discussed in Section 3.0 of
this document.
4.1 Nonwastewaters
Previous incineration tests conducted by the Agency are listed in
Table 4-1 at the end of this section. EPA examined the wastes incinerated in
these tests to determine their similarity to K025 nonwastewaters. Specifi-
cally, EPA examined (1) whether the untested K025 is generated from a similar
industry or processing step, and (2) whether the waste has similar waste
characteristics affecting treatment performance as do the previously tested
wastes.
Wastes included in Tests 3, 4, 5, 11, 12, 13, and 14 are generated
by the organic chemicals industry, as is K025. Several of these wastes are
distillation bottoms from the production of an organic chemical. However,
since K025 is generated in the production of nitrobenzene as distillation
bottoms, it contains nitrogenated organic compounds. Of the wastes generated
by a process similar to that generating K025, those incinerated in Tests 3, 4,
and 14 contain nitrogenated compounds and are therefore most structurally
similar to K025. The mixture of U and P wastes incinerated in Test 14
(Reference 3) was most similar to K025 in that it was also an organic,
nitrogen-containing waste with low water content.
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Wastes incinerated in Test 14 are expected to have similar thermal
conductivities to K025. Although the constituents of concern in K025 were not
incinerated in Test 14, several of the U and P wastes incinerated were similar
to these constituents with respect to structure: both the constituents in
K025 and the wastes represented in Test 14 included aromatic and organonitro-
gen compounds and alcohols. In addition, the wastes incinerated in Test 14
were similar to K025 with respect to physical properties that affect the
treatment performance of incineration, such as their boiling points. Because
of these similarities, it is believed that treatment performance similar to
that achieved for the surrogate U and P wastes incinerated in Test 14 could be
achieved for K02S nonwastewaters.
4.2 Wastewaters
The Agency examined all of the available wastewater treatment
performance data. Performance data for treatment of various industrial
wastewaters were developed by EPA's Office of Water. Additionally,
performance data from treatment of K103/K104 by liquid-liquid extraction
followed by steam stripping and activated carbon adsorption were the sole
source of data specifically for organonitrogen constituents. EPA examined
waste characterization data to evaluate the similarity between these wastes
and K025 wastewaters. Specifically, EPA examined (1) whether the untested
K025 is generated from a similar industry or processing step, and (2) whether
the waste has similar waste characteristics affecting treatment performance as
do the previously tested wastes.
Waste characterization data for the wastes tested by the Agency's
Office of Water were insufficient to compare these wastes to K025 in terms of
waste generation and waste characterization.
K103 is generated during aniline production, and both K025 and K104
are generated during nitrobenzene production. K02S is generated as distilla-
tion bottoms from the production of nitrobenzene, K103 is generated as process
residues from the production of aniline, and K104 is the combined wastewater
streams generated during nitrobenzene and aniline production. The industries
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generating these wastes were judged to be similar based on the organonitrogen
nature of the chemicals produced by these industries.
After determining that the wastes were generated by similar indus-
tries, EPA examined the relative treatability of K025 wastewaters and
K103/K104 wastewaters. As discussed in the Treatment Technology Background
Document (Reference 7), waste characteristics that affect treatment perfor-
mance of liquid-liquid extraction followed by steam stripping and carbon
adsorption include the boiling points of the waste constituents and the
concentrations of total organic carbon, total suspended solids, oil and
grease, and volatile organic compounds in the wastes.
K025 and K103/K104 are expected to contain the same, or similar,
constituents of concern and therefore would be expected to have similar
boiling points. The wastes are expected to have similar concentrations of
volatile organic compounds, total organic carbon, total suspended solids, and
oil and grease. Because of these similarities, the wastes are believed to be
similar and are expected to be treated to similar concentrations by liquid-
liquid extraction followed by steam stripping and activated carbon adsorption.
Additionally, the Agency believes that treatment performance similar
to that achieved for the surrogate U and P wastes incinerated in Test 14 could
be achieved for K025 wastewaters, for the same reasons discussed in Section
4.1 for K025 nonwastewaters.
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Table 4-1
WASTES TESTED BY INCINERATION AND SAMPLED BY EPA
Test Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Waste Code(s)
K001 - Pentachlorophenol
K001 - Creosote
K011, K013, K014
K019
K024
K037
K048, K051
K087
K101
K102
F024
K015
D014, D0161, P059*.
U127', and U192*
U1411, U028a, P020',
U1121, U226', U239*.
U080a, U220*. U166a,
U1611, and U188*
Treatment Technology Used
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Fluidized-bed incineration
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Rotary kiln incineration
Liquid injection
incineration
Rotary kiln incineration
Rotary kiln incineration
•Commercial chemical products were used in these test burns as surrogates for
these wastes.
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5.0 IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
This section presents the Agency's rationale for determining the
best demonstrated available technology (BOAT) for K025 nonwastewaters and
wastewaters.
To determine BOAT, 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 determined
by an analysis of variance (ANOVA) test. (The ANOVA test is discussed in
EPA's Methodology for Developing BOAT Treatment Standards (Reference 1).)
The treatment technology that is found to perform best on a par-
ticular waste stream is then evaluated to determine whether it is "avail-
able." To 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 question, provided that the similar waste is at least as difficult to
treat. If it is determined that the best performing treatment technology is
not available, then the next best technology is evaluated to determine whether
it is "available."
5.1 Review of Treatment Performance Data
The treatment performance data (presented in Section 4.0) for wastes
determined to be similar to K025 nonwastewaters and wastewaters were reviewed
and assessed to determine whether they represent operation of a well-designed
and well-operated treatment system, whether sufficient analytical quality
assurance/quality control measures were employed to ensure the accuracy of the
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data, and whether the appropriate measures of performance were used to assess
the performance of the particular treatment technology.
The treatment performance data and the design and operating data
collected during the test of rotary kiln incineration in Test 14 (Reference 3)
and of liquid-liquid extraction followed by steam stripping and activated
carbon adsorption (Reference 8) were reviewed for the points described above.
For both of these tests, the appropriate measure of performance (total
constituent concentration) was used to assess the treatment system. Addi-
tionally, the Agency had no reason to believe that these treatment systems
were not well-designed and well-operated, or that insufficient analytical
quality assurance/ quality control measures were employed in generating treat-
ment performance data.
5.2 Available Treatment Technologies
The demonstrated technologies for treatment of K025,
(1) incineration, and (2) liquid-liquid extraction followed by steam stripping
followed by carbon adsorption followed by incineration of spent carbon
(wastewaters only), are considered to be commercially available. These
technologies provide substantial treatment of the U and P wastes incinerated
in Test 14 and K103/K104. Since these U and P wastes and K103/K104 are
considered to be at least as difficult to treat as K025, the Agency believes
that incineration and liquid-liquid extraction followed by steam stripping and
activated carbon adsorption will also provide substantial treatment of K025.
Consequently, these technologies are considered available for treatment of
K025.
5.3 BOAT for K025
As discussed above, (1) incineration and (2) liquid-liquid
extraction followed by steam stripping followed by carbon adsorption followed
by incineration of spent carbon (wastewaters only) have been determined to be
demonstrated and available for treatment of K025. Because the Agency does not
have treatment performance data for any other demonstrated and available
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technologies for treating nonwastewater forms of K025 or similar wastes,
incineration is considered to be the best for nonwastewater forms of K025.
Therefore, the best demonstrated available technology (BOAT) for nonwastewater
forms of K025 has been determined to be incineration.
For wastewaters, in cases where the Agency has treatment performance
data for demonstrated and available wastewater treatment processes and
incineration (as measured by total constituent concentration in scrubber
water), the Agency prefers to establish treatment standards based on the
wastewater treatment processes. However, the Agency has determined that
wastewaters are also treated by incineration and does not intend to preclude
industry from continuing this practice. Therefore, the best demonstrated
available technologies (BOAT) for wastewater forms of K025 have been
determined to be (1) incineration, or (2) liquid-liquid extraction followed by
steam stripping followed by carbon adsorption followed by incineration of
spent carbon. Scrubber waters generated from the incineration of K025
nonwastewaters are considered to meet the treatment standard for K02S
wastewaters and do not require further treatment (see 54 Federal Register
26630 (June 23, 1989)). In addition, these BOAT technologies do not preclude
a facility from utilizing recycle or reuse operations in accordance with 40
CFR Part 261.
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6.0 DETERMINATION OF BOAT TREATMENT STANDARDS
The Agency prefers, whenever possible, to set concentration-based
treatment standards for listed wastes so as not to limit the selection of
those treatment technologies that may be used to achieve the BOAT treatment
standards. In cases where concentration-based standards cannot be determined,
EPA may choose to establish a method of treatment as the treatment standard.
Inherent in the establishment of concentration-based treatment
standards is the selection of constituents for regulation. EPA considers
several points in its selection of regulated constituents:
• How difficult a constituent is to treat, based on waste
characteristics affecting treatment performance;
• How representative a constituent is of others in the waste,
based on structural similarities; and
• How much of the constituent is present in the waste, based on
concentration levels.
The Agency has limited characterization data for K025 and does not believe
that, using the above criteria, these data are sufficient for evaluating which
constituents should be regulated in K025. EPA is uncertain whether other
constituents, which may not be controlled by regulation of the BOAT List
constituents quantified in K025, are present in K025. This uncertainty
precludes the selection of appropriate BOAT List constituents for regulation.
Accordingly, the Agency is establishing a method of treatment as the treatment
standard for nonwastewater and wastewater forms of K025, as discussed below.
6.1 Nonwastewaters
Incineration was determined to be BOAT for nonwastewater forms of
K025, as discussed in Section 5.0. Because incineration is a technology that
is applicable to treatment of most organic constituents, it is particularly
appropriate for treatment of K02S, since the identities and physical
properties of the waste constituents have not been fully identified.
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Accordingly, the Agency is establishing incineration as a method of treatment
for nonwastewater forms of K025.
6.2 Wastewaters
Incineration and liquid-liquid extraction followed by steam
stripping followed by activated carbon adsorption were determined to be BOAT
for wastewater forms of K025, as discussed in Section 5.0. The particular
appropriateness of incineration as treatment for K025 nonwastewaters, as noted
in Section 6.1, applies equally to K025 wastewaters. Accordingly, the Agency
is establishing (1) incineration, or (2) liquid-liquid extraction and steam
stripping followed by activated carbon adsorption as a method of treatment for
wastewater forms of K025.
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7.0 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 Jose
Labiosa, 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; Mary Willett,
Project Director; and Chrisanti Haretos, Task Leader.
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8.0 REFERENCES
1. USEPA. 1989. U.S. Environmental Protection Agency, Office of Solid
Waste. Methodology for Developing BOAT Treatment Standards. June, 1989.
Washington, DC.: U.S. Environmental Protection Agency.
2. American Public Health Association, American Water Works Association, and
the Water Pollution Control Federation. 1985. Standard Methods for the
Examination of Water and Wastewater. Sixteenth Edition. Washington,
DC.: American Public Health Association.
3. USEPA. 1989. U.S. Environmental Protection Agency, Office of Solid '
Waste. Onsite Engineering Report of the Third Thirds Incineration
Treatabilitv Test at the John Zink Company. Tulsa. Oklahoma. October,
1989. Washington, DC.: U.S. Environmental Protection Agency.
4. USEPA. 1986. U.S. Environmental Protection Agency, Office of Solid
Waste. Computer printout: Data on K025 Waste from the National Survey
of Hazardous Waste Treatment, Storage, Disposal, and Recycling Facilities
Database. Retrieved August, 1989. Washington, DC.: U.S. Environmental
Protection Agency.
5. USEPA. 1981. U.S. Environmental Protection Agency, Office of Solid
Waste. Identification and Listing of Hazardous Waste Under RCRA.
Subtitle C. Section 3001. May, 1981. Washington, DC.: U.S. Environmen-
tal Protection Agency.
6. USEPA. 1985. U.S. Environmental Protection Agency, Office of Solid
Waste. Characterization of Waste Streams Listed in 40 CFR Section 261
Waste Profiles. Two volumes. Washington, DC.: U.S. Environmental
Protection Agency.
7. USEPA. 1989. U.S. 'Environmental Protection Agency, Office of Solid
Waste. Treatment Technology Background Document. June, 1989. Washing-
ton, DC.: U.S. Environmental Protection Agency.
8. USEPA. 1987. U.S. Environmental Protection Agency, Office of Solid
Waste. Onsite Engineering Report of Treatment Performance and Operation
at E.I. duPont de Nemours. Inc.. Beaumont. TX. for K103 and K104.
December 22, 1987. Washington, DC.: U.S. Environmental Protection
Agency.
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