MEMORANDUM
TO:           Monica Chatmon-McEaddy                 cc:  J. Strauss
                                                          S. Schwartz
FROM:         Amanjit S. Paintal                          5254 File
DATE:         May 7, 1990
SUBJECT:      Final Treatment Standards for K069 Nonwastewaters in the
              Calcium Sulfate/Sodium Subcategory and Wastewater Forms of K069
        This memorandum presents the technical support and rationale for the
    development of treatment standards for K069 nonwastewaters in the Calcium
    Sulfate Subcategory and wastewater forms of K069.

    INTRODUCTION

        According to 40 CFR Part'261.32 (hazardous wastes from specific
    sources),  waste code K069 is listed as emission control dust/sludge from
    secondary lead smelting.   In the First Third Final Rule (53 FR 31165,
    August 17,  1988),  EPA established a Calcium Sulfate Subcategory and a
    Noncalcium Sulfate Subcategory for K069 nonwastewaters.  A final BOAT
    treatment standard of "norland disposal" based on  total recycle for those
    K069 nonwastewaters in the Noncalcium Sulfate Subcategory was promulgated
    in 53 FR 31165 (Table 24).   Treatment standards for K069 nonwastewaters
    in the Calcium Sulfate Subcategory and wastewater  forms of K069 were not
    promulgated as part of the First Third rulemaking  in order to allow the
    Agency time for additional data collection and analysis.

    INDUSTRY AFFECTED

        The Calcium Sulfate  Subcategory of K069 nonwastewaters was defined by
    EPA in 53  FR 31165 to cover a  single plane (Exide/GBC)  which,  to EPA's
    knowledge,  is the  only plant generating a K069 nonwastewater  stream that
    3557g-l

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 cannot be  directly  recycled  to  recover  lead.   (Lead  recovery  is  the
 treatment  standard  that was  promulgated for  the Noncalcium  Sulfate
 Subcategory  for nonwastewaters.)  This  stream  is  a dewatered  venturi
 scrubber sludge resulting  from  the  lime slurry scrubbing  of residual
 gases from fabric filtration of secondary  lead smelter  offgases.  The
 resulting  wastewater  after sludge dewatering is the  "derived  from"
 wastewater form of  K069.   This  wastewater  can  also be generated  as
 leachate from RCRA  or CERCLA land disposal activities.

 WASTE CHARACTERIZATION

    A.  Wastewaters.  The  only  known characterization data  for K069
 wastewaters  are available  in an Office  of Water,  Effluent Guidelines
 Division,  draft development  document (USEPA 1977).   These
 characterization data describe  venturi  scrubber water generated  at the
 one secondary lead  smelting  plant.  Table  1 presents the pertinent data
 on BDAT list metal  constituents from this  source.

    The Agency believes that KCf>9 wastewater represents a single
 treatability group  based on  its expected physical and chemical
 composition.  Specifically,  K069 wastewaters are  expected to  be  similar
 in physical  and chemical composition regardless of how  they are
 produced.  Hence, K069 wastewaters have not been  subcategorized.

    B.  Nonwastewaters.  Characterization data submitted by Exide/GBC
 in response  to the  First Third  Proposed rulemaking for  K069 waste are
 summarized in Table 2.  These data cover the principal  parameters
 characterizing the  Calcium Sulfate Subcategory of K069  nonwastewaters.
3557g-2

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          Table 1  Venturi Scrubber Water Characterization Data at
                the Single Calcium Sulfate Subcategory Plant
    Constituent                          Scrubber  water analyses (mg/1)
        Arsenic                                       1.25
        Cadmium                                       1.62
        Lead                                         54

        pH                                            1.5
Source:  USEPA  1977.
3557g-3

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                            Table  2   Suimarized  Characterization  Data  for  the  Calcium Sulfate
                                           Subcategory of K069 Nonwastewaters
Parameter
Metals content (Total analysis
Arsfen ic
Bar mm
Cadmium
Total chromium
Mercury
Nickel
Se It'M ium
Si Ivtr
Copper
Molybdenum
Zinc
Lead

TCLP leachate, test
Cadmium
Lead
EP leachate. test
Value or
range 'TCLP EP mg/1 Comments
- wet basis) , ppm
494
56
13-130
10
515
8
23-130
3
22
2
16
650-3327 Too low to recycle to lead
smelter for recovery of lead

0.21-1.47
0.66-0.72

  Arsenic
  Barium
  Cadmium
  Total chromium
  Lead
  Mercury
  Se Ifnium
  Silver
<0.1-3.08
<0.1-2.9
0.1-13.7
0.007-0.27
0.085-24.3
<0.02-0.11
0.002-0.36
0.01-0.07
 Other Parameters
   Percent solids                     20-61
   pH (solids  in water)               6-12
   Heat ing value                      N/A
   Ignit ability                       N/A
  Sulhite/sulfite content, %         31
  Oi1 dnd grease,  %                  <0.02
  Orgariics,  ppm                      <1
                   Typically around 40
                   Waste is not ignitable
Source-  Morgan. Lewis, and Backius  1988.

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APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES

    A.  Wastewaters.  For K069 wastewaters,  the Agency believes  that
the applicable treatment technologies include chemical precipitation
followed by settling  and/or filtration.  The Agency has  identified  these
treatment technologies because they are designed  to reduce  the
concentration of metals in wastewaters.  In  addition, the treatment
system consisting of  chemical precipitation  followed by  settling and/or
filtration is an applicable technology for removal of both  dissolved and
suspended metals from K069 wastewaters.  Other applicable technologies
include ion exchange  and physical  treatment  methods that remove suspended
solids from wastewaters (such as clarification, flocculation, vacuum
filtration, sludge  thickening, and other similar  technologies).   Chemical
precipitation, followed by settling, filtering, and dewatering of solids
are widely practiced  metals treatment technologies (USEPA 1986a).
Physical separation methods such as clarification, flocculation,
filtration, and sludge thickening  are also demonstrated  treatment
technologies for removal of metals from wastewaters.

    B.  Nonwastewaters.  Applicable treatment for the Calcium Sulfate
Subcategory of K069 nonwastewater  is stabilization to reduce the
leachability of BOAT  list metals.

    All of the applicable wastewater and nonwastewater treatment
technologies are demonstrated because they are used on a full-scale
commercial basis for  treatment of  metal bearing wastes.  Metals
precipitation, followed by settling, filtering, and dewatering of solids,
and stabilization are widely practiced metals treatment  technologies.

    Additional information on technologies identified as applicable for
K069 wastes can be  found in the Treatment Technology Background Document
(USEPA 1989)
3557g-5

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PERFORMANCE DATA

    This section discusses all available performance data associated with
K069 nonwastewaters in the Calcium Sulfate Subcategory and wastewater
forms of K069.

    A.  Wastewaters.  The only treatability data relative to K069
wastewaters are from the Exide/GBC lead smelting plant.  At this
facility, K069 wastewater is sent to an onsite industrial wastewater
treatment plant where it is lime-treated, clarified, and filtered in
combination with other plant wastewaters.  The treatability data for the
combined wastewaters including waste code K069 have appeared in the
previously referred to ELG document, and are presented in Table 3.
Additional plant data (from the same ELG document) based on alkaline
treatment (chemical precipitation) for lead and arsenic are shown in
Table 4.

    In addition, the Agency has 11 data sets for treatment of metal-
bearing wastewaters by hexavalent chromium reduction, chemical
precipitation, and dewatering of the precipitate.  These data are
presented in Tables 5 through 15.   The metal bearing wastewaters included
waste code K062, and these data were previously used in the development
of treatment standards for K062 in the First Third Final Rule (USEPA
1988b).   The Agency believes that these K062 data can be used to assess
the performance of these technologies for K069 wastewaters, since the
untreated K062 wastewaters contain much higher concentrations for most
metals than K069 wastewaters are expected to contain.  Accordingly, EPA
is using these performance data for treatment by hexavalent chromium
reduction,  chemical precipitation, and dewatering of the precipitate to
promulgate treatment standards for cadmium in K069 wastewaters.
3557g-6

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        Table 3  EPA-Collected Data  on Alkaline  Treatment  (Chemical
            Precipitation)  of Secondary Lead Smelter Wastewaters
                                  Influent                 Effluent
                               concentration            concentration
Constituent                        (mg/1)                   (mg/1)
Pb
As
Cd
76
0.024
0.83
0.41
0.03
0.005
    pH                             1.3                      8.85
Source:  USEPA 1977, Table VII-15, p.  187.  Analyses are on
  composite samples of  influent and effluent.
3557S-7

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            Table 4  Monthly  Plant-Collected  Effluent Data Following
                   Alkaline Treatment (Chemical Precipitation)
                              on BDAT Constituents
Year 197S

Month
January
February
March
April
May
June
July
Augus t
September
October
November
December
Selected Consti tuenr Ff fluent Level (me/1)
pH
Average
7.72
7.33
7.57
8.14
7.54
8.03
8.31
7.94
7.93
8.12
Pb
Average
0.39
0.37
0.57
0.35
0.36
0.104
<0.072
0.16
0.228
0.155

Maximum
2.24
1.63
1.43
0.88
2.30
0.32
0.17
0.74
2.65
0.81
As
Average
<0.004
<0.004
<0.009
<0.007
<0 . 004
0.003
<0.002
0.003
0.003
0.004

Maximum
0.037
0.015
0.033
0.027
0.026
0.008
0.002
0.019
0.007
0.027
 Source:  USEPA  1988.
3557g-8

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    The Agency has data  indicating  that K069 wastewaters may contain
higher concentrations of lead than  is typically found  in K062 wastewaters.
Therefore, the Agency evaluated available wastewater data for treatment  of
lead.  The Agency evaluated the 15  data sets for treatment of D008  (lead)
wastewaters from the foundry industry (Tischler/Kocurek - LD12-00027).
These treatment performance data are presented in Tables 16 and 17.  The
D008 wastewaters are generated from the emission control scrubbers  from
the production of iron castings, and are treated by a  system consisting
of chemical precipitation, flocculation, clarification, filtration, and
sludge thickening.

    EPA evaluated the D008 data with respect to characteristics that
affect treatment performance.  Specifically, the D008  data were
determined to be similar to K069 wastewaters in terms  of the
concentration of lead.   In fact, the D008 had higher untreated lead
concentrations than K069 wastewaters, (50-276 mg/1 compared to 76 mg/1).
Also, the D008 waste lead concentration was substantially reduced (from
as high as 276 mg/1 of lead in influent to as low as 0.17 mg/1 of lead
effluent) by the treatment system consisting of chemical precipitation,
flocculation, clarification, filtration, and sludge thickening.   The
performance data for the D008 waste is shown in Table  16.   Based on these
D008 data, the Agency would expect  that these D008 wastewaters would be
more difficult to treat  than K069 wastewaters.  The Agency also believes
that these two wastes probably have similar characteristics because both
are emission control dust sludges from high temperature processes.
Accordingly,  the Agency is using D008 treatment data  to assess the
performance of lead in K069 wastewaters.

    B.   Nonwastewaters.   Treatment performance data for the Calcium
Sulfate Subcategory of K069 nonwastewaters specifically are not
available.  However,  performance data are available from stabilization
rests on F006 and K061 nonwastewaters,  which are believed ~o be similar
3557g-9

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to K069 nonwastewater in the Calcium Sulfate Subcategory in that both
F006 nonwastewaters and K061 nonwasterwaters contain similar metal
constituents in higher concentrations than do K069 nonwastewaters.  The
data presented in Table 18 represent performance data developed from
stabilization of F006 waste, while the data in Table 19 represent
treatment of K061 wastes.  These data were previously used in the
development of treatment standards for F006 and K061 in the First Third
Final Rule (USEPA 1988a,c).

DETERMINATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY CBDAT") FOR K069

    This section presents the rationale for the determination of best
demonstrated available technology (BDAT) for K069 nonwastewaters in the
Calcium Sulfate Subcategory and wastewater forms of K069.

    The Agency examined all the available treatment performance data for
the demonstrated technologies to determine which is best.   For K069
wastewaters,  the Agency has treatment performance data for one facility
that treats K069 wastewaters using chemical precipitation.  In addition,
treatment performance data are available for metal-bearing wastewaters
containing K062 waste, which the Agency has shown to be similar to K069
wastewaters (see section in Performance Data).   Based on an evaluation of
the untreated waste characteristics that affect treatment performance of
these technologies,  the Agency has determined that K062 wastewaters are
more difficult to treat than K069 wastewaters for cadmium.  Also
available are treatment performance data for D008 wastewaters that are
similar to K069 wastewaters with respect to lead concentrations.  Based
on an evaluation of these data (see section in Performance Data Base),
the Agency has determined that for lead the D008 wastewater is more
difficult to  treat than K069 wastewaters.
                                     10
3557g-10

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3201g
          Table 5  Treatment Perfonnance Data for K062   EPA-Collected Data
                                    Sample Set tl
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromimi (total)
Copper
Lead
Nickel
Zinc


Untreated
K062 waste
(mg/1)
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Design
Design
Untreated
K062 waste
(mg/D
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
and Operating Data
value
Untreated
waste
composite3
(g/D
Sample No.
805
<1
13
893
2581
138
64
471
116

Operating
Treated
waste
(wastewater)
(mg/D
Sample No.
806
<0.1
<0.5
0.011
0.12
0.21
<0.01
0.33
0.125

value
PH
                                  8-10
I = Color interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-K062 waste streams.

Source:  USEPA 1988b.
                                     11

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 3201g
           Table 6  Treatment  Performance  Data  for  K062    EPA-Collected Data
                                     Sample Set #2
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc


Untreated
K062 waste
(rag/D
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Design
Design
Untreated
K062 waste
(mg/D
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
and Operating Data
value
Untreated
waste
composite9
(mg/D
Sample No.
813
<1
10
807
2279
133
54
470
4

Treated
waste
(wastewater)
(mg/1)
Sample No.
814
<0.1
<0.5
0.12
0.19
0.15
<0.01
0.33
0.115

Operating value
PH
8-10
I = Color interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-K062 waste streams.

Source:  USEPA 1988b.
                                       12

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3201g
          Table 7  Treatment Performance Data for K062 - EPA-Collected Data

                                    Sample Set f3

Constituent
Arsenic
Caotaiium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc



Untreated
K062 waste
(mg/1)
Sample No.
817
3
<5
I
1700
425
<10
100310
7
Design
Design

Untreated
K062 waste
(mg/1)
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
and Operating Data
value
Untreated
waste
composite9
(mg/D
Sample No.
821
<1
5
775
1990
133
<10
16330
3.9

Operating
Treated
waste
(wastewater)
(mg/D
Sample No.
822
<0.1
<0.5
I
0.20
0.21
<0.01
0.33
0.140

value
PH
                                  8-10
10
I = Color interference.


aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-K062 waste streams.

Source:  USEPA 1988b.
                                           13

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   3201g
                   Table 8  Treatment  Performance  Data  for  K062  -  EPA-Collected Data


                                            Sample Set /4
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc
Untreated
062 waste
(mg/D
Sample No.
827
2
<5
1
142
42
<10
650
3
Untreated Untreated
K062 waste K062 waste
(mg/1) (mg/1)
Sample No. Sample No.
802 817
<1 3
<5 5
I I
7000 1700
306 425
<10 <10
2600 41000
<2 7
Untreated
waste
composite3
(rag/D
Sample No.
829
<1
<5
0.6
556
88
<10
6610
84
Treated
waste
(wastewater)
(mg/D
Sample No.
830
<1
<0.5
0.042
0.10
0.07
<0.01
0.33
1.62
Design and Operating Data

PH
Design
8-10
value Operating
9
value



I = Color  interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this
 table, along with other non-K062 waste streams.

Source:  USEPA 1988b.
                                           14

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3201g
                 Table 9  Treatment  Performance  Data  for  K062    EPA-Collected  Data
                                           Sample  Set #5
Constituent
Arsenic
Cadmium
Chromiun (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc
Untreated
K062 waste
(mg/D
Sample No.
801
3
<5
I
1800
865
<10
3ZOO
<2
Untreated
K062 waste
(mg/1)
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
Untreated
K062 waste
(mg/D
Sample No.
817
3
5
I
1700
425
<10
41000
7
Untreated
waste
composite9
(mg/D
Sample No.
837
<1
<5
917
2236
91
18
1414
71
Treated
waste
(wastewater)
(mg/1)
Sample No.
838
<0.1
<0.5
0.058
0.11
0.14
0.01
0.31
0.125
Design and Operating Data
Design value
Operating
value

pH
                                  8-10
I = Color interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams  shown on this
 table, along with other non-K062 waste streams.

Source:  USEPA 19885.
                                         15

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 3201g
          Table 10  Treatment Performance Data for K062   EPA-Collected Data

                                     Sample  Set #6
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc


Untreated
K062 waste
(rag/D
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Design
Design
Untreated
K062 waste
(rag/1)
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
and Operating Data
value
Untreated
waste
composite
(mg/1)
Sample No.
845
<1
<5
734
2548
149
<10
588
4

Operating
Treated
waste
(wastewater)
(mg/D
Sample No.
846
<0.1
<0.5
I
0.10
0.12
<0.01
0.33
0.095

value
                                  8-10
I = Color interference.


aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-K.062 waste streams.

Source:  USEPA 1988b.
                                          16

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3zuig
          Table 11  Treatment Performance Data for K062   EPA-Collected Data
                                    Sample Set #7
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromiim (total)
Copper
Lead
Nickel
Zinc


Untreated
K062 waste
(mg/D
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Design
Design
Untreated
K062 waste
(mg/1)
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
and Operating Data
value
Untreated
waste
composite3
(rag/1)
Sample No.
853
<1
10
769
2314
72
108
426
171

Operating
Treated
waste
(wastewater)
(rog/D
Sample No.
854
<0.1
<0.5
0.12
0.12
0.16
<0.01
0.40
0.115

value
PH
8-10
I = Color interference.


aThe untreated waste composite is a mixture of the untreated K.062 waste streams
 shown on this table, along with other non-K062 waste streams.

Source:  USEPA 19886.
                                        17

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3201g
          Table 12  Treatment Performance Data for K062   EPA-Collected Data
                                    Sample Set #8
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc
Untreated
K062 waste
(mg/1)
Sample No.
859
<1
<5
0.220
15
151
<10
90
7
Untreated
K062 waste
(mg/D
Sample No.
801
3
<5
I
1800
865
<10
3200
9
Untreated
waste
composite3
(mg/D
Sample No.
861

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                Table 13  Treatment Performance Data for K062   EPA-Collected Data

                                           Sample  Set  #9
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc
Untreated
K062 waste
(mg/1)
Sample No.
867
<0.1
<0.5
0.079
6
5
<1
4
0.4
Untreated
K062 waste
(mg/1)
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Untreated
K062 waste
(mg/1)
Sample No.
802
<1
<5
I
7000
306
<10
2600
<2
Untreated
waste
composite3
(mg/1)
Sample No.
869
<1
<5
0.07
939
225
<10
940
S
Treated
waste
(wastewater)
(mg/1)
Sample No.
870
<0.1
<0.5
0.041
0.10
0.08
<0.01
0.33
0.06
Design and Operating Data
PH
                               Design value

                                  8-10
Operating value

       10
I = Color interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this
 table, along with other non-K062 waste streams.

Source:  USEPA 1988b.
                                          19

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 3201g
          Table 14  Treatment Performance Data for K062   EPA-Collected Data
                                    Sample Set #10
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc


Untreated
062 waste
(9/1)
Sample No.
801
<3
<5
I
1800
865
<10
3200
<2
Design and
Design
Untreated
waste
composite3
(9/1)
Sample No.
885
<1
<5
0.08
395
191
<10
712
5
Operating Data
value
Treated
waste
(wastewater)
(mg/D
Sample No.
862
<0.10
<0.5
0.106
0.12
0.14
<0.01
0.33
0.070

Operating value
pH
8-10
I = Color interference.


aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-K062 waste streams.

Source:   USEPA 1988b.
                                       20

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          Table 15  Treatment Performance Data for K062 - EPA-Collected Data
                                    Sample Set til
Constituent
Arsenic
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Nickel
Zinc


Untreated
K062 waste
(mg/1)
Sample No.
801
3
<5
I
1800
865
<10
3200
<2
Design
Design
Untreated
K062 waste
(rag/1)
Sample No.
859
<1
<5
0.220
15
151
<10
90
7
and Operating Data
value
Untreated
waste
composite3
(mg/1)
Sample No.
893
<1
23
0.30
617
137
136
382
135

Operating
Treated
waste
(wastewater)
(mg/D
Sample No.
894
<0.10
<5
<0.01
0.18
0.24
<0.01
0.39
0.100

value
                                  8-10
I = Color interference.
aThe untreated waste composite is a mixture of the untreated K062 waste streams
 shown on this table, along with other non-(C062 waste streams.

Source:  USEPA 1988b.
                                       21

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3201g
        Table 16  Treatment Performance Data for 0008 Vastewater
Sample set no.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Influent concentration
(mg/1)
66.7
91.7
83.3
276.0
50.0
50.0
58.3
58.3
134.0
200.0
100.0
116.0
91.7
100.0
116.0
Effluent concentration
(mg/D1
0.17
0.25
0.25
0.33
0.17
0.25
0.33
0.33
0.33
0.25
0.33
0.25
0.33
0.42
0.33
  Recovery data 115 percent and 112 percent.   Analytical recovery
  data show two recovery values,  115 & 112 percent.   Because both values
  exceeded 100X,  the effluent data were not corrected to lower values,
  but are considered at the uncorrected level.  (See Methodology
  Document - Hay 89).

Source:  Tischler/Kocurek (LD12-00027)
                                        22

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          Table  17   Design  and Operating Data for 0008 Wastewater Treatment
                                   Performance  Data
Sample set no.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Chemical addition:
Cationic polymer
Anionic polymer
TSS (mg/1)
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
4
5
6

1.5 ppm
0.5 ppm
16 percent high magnesium lime
Flow (6PM)
1300
1285
1291
1274
1296
1285
1305
1295
1285
1290
1250
1250
1300
1262
1307



4.26 6PM
PH1
8.9
9.2
9.2
9.0
9.1
8.8
9.1
9.2
9.1
9.2
8.7
8.6
8.8
9.2
9.4




PH2
8.8
9.2
9.3
9.2
9.2
8.8
9.2
9.3
9.2
9.2
8.5
8.6
8.8
9.1
9.2




  pH of recycle to clarifier.
  pH in clarifier.
Source:  Tischler/Kocurek. (LD12-00027)
                                         23

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Table 18  Treatment Performance Data for Stabilization of F006 Nonwastewater
Nix
Source ratio
Unknown
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.2
Auto part manufacturing
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.5
Aircraft overhauling
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
Zinc plating
Unstabilized
As received
TCLP
Stabilized
TCLP 0.5
Unknown
Unstabilized
As received
TCLP
Stabilized
TCLP 0.5
Metal concentrations (ppm)
Barium Cadmium Chromium Copper Lead Nickel


435
0.71

0.05


31.3 755 7030 409 989
2.21 0.76 638 10.7 22.7

0.01 0.45 0.27 0.39 0.03


85.5 67.3 716 - - 259
1.41 1.13 0.43 - - 1.1

0.34 0.06 0.09 - - 0.27


17.2 1.30 - 1510 - 37
0.84 0.22 - 4.6 - 0.52

0.25 0.01 - 0.21 - 0.02


14.3 720 12.200 160 - 701
0.38 23.6 25.3 1.14 - 9.78

0.21 0.01 0.44 0.31 - 0.04

Silver Zinc


1560
0.16

0.03


6.62 4020
0.14 219

0.06 0.01


631
5.41

0.03


9.05 90.200
0.16 2050

0.05 0.04


25.900
867

0.03

-------
                                                                    Table  18   (continued)
Nix
Source ratio3
Small engine manufacturing
Uns tab ill zed
As received
TCLP
Stabilized
TCLP 0.5
Circuit board manufacturing
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.5
ro
en
Unknown
Unstabilized
As received
TCLP
Stabilized
TCLP 0.5
Unknown
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.5
Metal concentrations
Barium Cadmium Chromium Copper


7.28 3100 1220
0.3 38.7 31.7

0.01 0.89 0.31


5.39 42.900 10.600
0.60 360 8.69

0.01 1.41 0.45


15.3 5.81 - 17.600
0.53 0.18 - 483

0.294 0.01 - 0.35


19.2 - - 27.400 24.
0.28 - - 16.9

0.087 - - 0.50
(ppm)
Lead Nickel


113 19.400
3.37 730

0.39 0.06


156 13,000
1.0 152

0.41 0.11


169 23.700
4.22 644

0.40 0.04


500 5.730
50.2 16.1

0.29 <0.02

Silver Zinc


4.08 27.800
0.12 1200

0.06 0.040


120
0.62

0.020


8.11 15.700
0.31 650

0.06 0.020


322
1.29

<0.01
aAdjusted analytical results (referred to as accuracy-corrected concentrations) used for comparing the performance of one technology to that of another

 and for calculating treatment standards for those constituents to be regulated.




b             we i glit of reagent
  Mix ratio =
               weiyht of waste


Source:   USEPA 1988a.

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      Table 19  Summary of Treatment Performance Data for Stabilization
              of K061 Nonwastewater Using  a  Lime/Flyash Binder
                             (EPA Collected Data)
Untreated waste
Constituents
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Oil and grease
Sulfates
Chlorides
TOC
Total
(ppm)
294
36
238
0.15
481
1,370
2,240
20,300
3.8
243
<5.0
59
<1.0
25
244,000
282
8,440
19,300
4,430
TCLP
(mg/1)
0.040
<0.010
0.733
<0.001
12.8
<0.007
0.066
45.1
0.0026
0.027
<0.050
0.021
0.038
<0.006
445




Treated waste
TCLP
(mg/1)
<0.050
<0.010
0.431 -
<0.001
0.033 -
0.053 -
<0.004 -
0.066 -
0.0016
<0.012
<0.025
<0.003
0.011 -
0.080 -
0.179 -






0.500

0.073
0.093
0.015
0.150
- 0.0018



0.014
0.089
0.592




Source:  USEPA  1988c
                                     26
3557g-26

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    Treatment performance data are not available for the Calcium Sulfate
Subcategory of K069 nonwastewaters specifically.  However, performance
data are available from stabilization tests on F006 and K061
nonwastewaters and can be used for treatment of K069 nonwastewater
because both F006 and K061 nonwastewater contain similar metal
constituents in higher concentrations than do K069 nonwastewaters.

    A.  Wastewaters.  Based on the comparison of metal concentrations
in the untreated wastes (i.e., as high as 13 mg/1 of cadmium  (Table 5)
and 212 mg/1 lead (Table 12)  in untreated K062 wastewaters compared to as
high as 1.62 mg/1 cadmium (Table 1), and 76 mg/1 lead  (Table  3) in
untreated K069 waste), the Agency has determined that K062 wastewaters
are more difficult to treat than K069 wastewater for cadmium.

    Available treatment performance data presented in Tables  5 through 15
for treatment of K062 wastewaters by chromium reduction, chemical
precipitation, and filtration show that this treatment is effective.
Cadmium was reduced from as high as 13 mg/1 to <0.5 mg/1; and lead was
reduced from as high as 212 mg/1 to <0.01 mg/1.  These data collected
from this treatment train for K062 wastewaters were obtained  from a
well-designed and well-operated system and therefore can be used to
compare treatment performance of demonstrated technologies.  Based on the
evaluation of the available treatment performance data and other
information, the Agency believes that the treatment train consisting of
hexavalent chromium reduction, chemical precipitation and settling,
and/or filtration represents  BDAT for cadmium in K069 wastewaters.

    Even though K062 data could be used to evaluate treatment of lead in
K069 wastewaters, the treatment data for K062 wastewaters,  however, were
not used because during the Third Third comment period, EPA received D008
(lead) wastewater data (Tischler/Kocurek-LD12-00027) showing higher lead
concentration in untreated D008 waste than in both K062 and K069.   These
                                     27
3557g-27

-------
data are shown on Table 16.  D008 treatment data (15 data sets) showed
treatment was possible to 0.17-0.42 mg/1 for lead.  Since D008 wastewater
data have higher untreated lead concentration than both K069 and K062
wastewaters (i.e., D008 should be more difficult to treat than either
K062 or K069), EPA is using these data to calculate the treatment
standard for  lead (See Table 21).  The D008 data were collected from a
well-designed and well-operated treatment system consisting of chemical
precipitation, flocculation, clarification, filtration, and sludge
thickening.   Also submitted for D008 treatment were effluent values
without the corresponding untreated data.  These data could not be used
in EPA's evaluation of the treatment system.  However, they are presented
in Appendix A.

    The Agency believes that the D008 wastewater treatment data for
chemical precipitation, flocculation, clarification, filtration, and
sludge thickening represents BDAT for lead in K069 wastewaters.  The
treatment performance data demonstrate substantial reduction of the
concentration of lead in wastewaters, from levels as high as 276 mg/1 to
as low as 0.17 mg/1 (see Table 16).   Therefore,  the Agency is
transferring  the D008 wastewater treatment performance data for lead to
K069 wastewaters, with the above-mentioned treatment train representing
BDAT for lead in K069 wastewaters.

    For cadmium,  in K069 wastewater the treatment standard is based on
the performance of chemical precipitation for K062 wastewaters.  For
lead,  in K069 wastewaters the treatment standard is also based on the
performance of chemical precipitation,  but in D008 wastewaters.  As noted
above,  the Agency believes that D008 wastewaters better represent lead
treatment in K069 wastewaters.   Since both the K062 and D008 treatment
trains  use the same technology (i.e., chemical precipitation) as a method
of removing metals from wastewater,  EPA believes that the use of K062
                                    28
3557g-28

-------
wastewater data  for cadmium  regulation  in K069 wastewater  is compatible
with the use of  D008 wastewater  data  for lead regulation in K069
wastewater.

    Based on the evaluation  of the available treatment performance data
and other information,  the Agency has determined that the  treatment train
consisting of hexavalent  chromium reduction, chemical precipitation,
filtration, clarification and sludge  dewatering is BOAT for K069
wastewaters for  treating  both cadmium and lead.

    B.  Nonwastewaters.   EPA compared the F006 and K061 wastes to
determine which  would be  more representative of K069 nonwastewaters in
the Calcium Sulfate Subcategory.  Included  in this analysis were waste
parameters that  affect  the stabilization treatment such as concentrations
of metals, sulfide levels, and waste  generation information.  In general,
both K061 nonwastewaters  and F006 nonwastewaters contain similar metal
constituents in  higher  concentrations than  do K069 nonwastewaters.  The
sulfate levels in both  K061  and  F006  are insignificant compared to the
high sulfate level in K069.  The industrial process by which the K061
nonwastewater sludge is generated more  closely resembles the process that
generates the K069 nonwastewater (both  are  emission control dust
sludges).  Based on this  analysis, EPA  considers the K061 nonwastewaters
more representative than  F006 nonwastewaters of K069 nonwastewaters in
the Calcium Sulfate Subcategory.

    The data on  generation of the K069  wastes in the Calcium Sulfate
Subcategory indicate that during the generation of this waste,  excess
lime is added to the K069 as it  is being generated.  This excess lime is
expected to act  as a stabilizing agent, with the resulting waste
exhibiting a lower leachability  than would be expected from a waste that
was generated without the addition of excess lime.  Conversely,
characterization data of  this waste indicate a high level of sulfates in
                                     29
3557g-29

-------
the waste, which affects treatment performance of some solidification
processes.  Regardless of the high level of sulfates, the Agency believes
that substantial treatment levels is achievable simply by the  current
practice of addition of excess lime during generation.  Therefore,  EPA
believes that the data on stabilization of K061 can be used  to establish
treatment performance standards for K069 nonwastewaters in the Calcium
Sulfate Subcategory.

    Available treatment performance data presented in Table  19 for
stabilization of K061 nonwastewater using a lime/flyash binder show that
this treatment is effective.  Stabilization technology adopted as BOAT
for the Low Zinc Subcategory of K061 nonwastewater was able  to  produce
TCLP leachate levels of 0.066 to 0.150 mg/1 lead and 0.033 to  0.073  mg/1
cadmium from a K061 nonwastewater containing 20,300 ppm lead and 481  ppm
cadmium.  Based on this analysis and other data and information explained
in the K061 Background Document (USEPA 1988a),  the Agency maintains  that
stabilization using a lime/flyash binder represents BDAT for K069
nonwastewaters in the Calcium Sulfate Subcategory.

SELECTION OF REGULATED CONSTITUENTS

    A.  Wastewaters.  The BDAT list metals found in treatable
concentrations in the untreated K069 wastewater (see Table 1)  are lead
and cadmium.  Arsenic was also present in low concentrations,  but is
expected to be treated and controlled along with the lead and  cadmium.
Based on these findings, the regulated constituents for which  EPA is
promulgating standards are lead and cadmium.

    B.  Nonwastewaters.   Leachate data for K069 nonwastewaters  in the
Calcium Sulfate Subcategory (see Table 2)  show that lead and cadmium  are
present at treatable concentrations,  and that while other metal
constituents are present at lower concentrations.   The Agency  does not
                                    30
3557g-30

-------
expect  the presence  of  other  BDAT metals  at  treatable  levels.
Furthermore,  other BDAT list  metal  constituents  that are not regulated
are expected  to be treated by a well-designed and well-operated  treatment
system.  Based on these findings, the regulated  constituents are lead and
cadmium.

CALCULATION OF BDAT  TREATMENT STANDARDS

    This section presents the treatment standards for  the regulated
constituents  described  previously.  A description of the rationale and
procedures for calculating treatment standards is presented in the K062
wastewater background document (1988b) and K061  nonwastewater background
document (1988a) and D008 (Final Background  Document (USEPA, 1990).  The
BDAT treatment standards presented  in this section  (1) are reflective of
treatment performance data from a well-designed  and well-operated
treatment system, (2) account for analytical limitations, and (3) have
been adjusted for variability caused by treatment, sampling, and
analytical techniques and procedures.

    A.  Wastewaters.  Treatment Standards for Cadmium:  EPA compared
the K062 wastewaters with the K069  waste  stream  shown  in Table 1 with
regard  to concentrations of metals.  In general, both  K069 wastewaters
and K062 wastewaters contain  similar metal constituents, but cadmium in
K062 wastewaters had higher concentrations than  cadmium in K069
wastewaters.  Therefore, for  cadmium, EPA would  expect that the K062
wastewaters would be more difficult to treat effectively by the selected
BDAT treatment system consisting of chemical precipitation,  settling,
and/or  filtration.

    Based on  the available data relative  to waste characteristics,  the
Agency has no reason to believe that for cadmium the treatment levels
achieved for  K062 wastewaters  cannot be achieved for K069 wastewaters
                                     31
3557g-31

-------
Accordingly. EPA is using these performance data for chemical
precipitation, and settling and/or filtration to establish treatment
standards for cadmium in K069 wastewaters.  Therefore, the Agency  is
transferring the treatment performance data from this treatment train  for
cadmium in K062 wastewaters to K069 wastewaters.

    The 11 data sets for treatment of K062 wastewaters by chemical
precipitation and dewatering of the precipitate were determined to
represent treatment by a well-designed and well-operated treatment system
(USEPA 1988b).  One data set for cadmium was deleted (Sample Set #11)
because of an artificially high detection limit of 5 mg/1 for cadmium,
deviating from the other 10 data points,  which had detection limits of
0.5 rag/1.

    Treatment Standards for Lead:   The 15 data sets for treatment of
lead in D008 wastewaters by chemical precipitation, flocculation,
clarification, filtration,  and sludge thickening were determined to
represent treatment by a well-designed and well-operated system.   (See
Table 16 and 17).   The 15 effluent treatment points for lead were
corrected for analytical recovery by multiplying the data by the
appropriate correction factor.   The correction factor was calculated from
the recovery data submitted with the data for the treatment tests
(Tischler/Kocurek,  1989).   Both of the recovery figures (115 and 112
percent) were greater than 100 percent.   Therefore, a correction factor
of 1.00 is used and the corrected values  equal the original data values
(see Methodology Document,  May 89).  The  corrected values for the two
regulated constituents in the K069 wastewaters are presented in Table 20.

    An arithmetic average of accuracy-corrected concentration levels for
each regulated constituent and a variability factor for each regulated
constituent were then calculated.   The treatment standard for each
                                    32
3557g-32

-------
regulated  constituent was  calculated  by  multiplying  the  average  accuracy-
corrected  data by  the appropriate variability  factor.  The  calculation  of
the treatment standards  for K069 wastewaters is presented in Table  21.

    Table  22 presents the  specific  BDAT  treatment  standards for  K069
wastewater.  For the BDAT  list metal  constituents, treatment standards  in
the wastewater reflect the total constituent concentration.  The units
for the total constituent  concentration  are mg/1  (parts  per million on  a
weight-by-volume basis)  for the wastewater.  If the  concentrations of the
regulated  constituents in  the K069, as generated,  are lower than or equal
to those of the BDAT treatment standards,  then treatment is not necessary
as a prerequisite  to land  disposal.

    B.  Nonwastewaters.  Specifically, EPA believes  that the data on
stabilization of K061 waste can be  used  to assess  treatment performance
for cadmium and lead in  K069 nonwastewaters.

    The Agency considered  the K069  treatment sludge  data submitted to the
Agency in  response  to the  Third Third Proposed Rule.  No treated
(stabilized) data was provided to the Agency for evaluation.  The K069
treatment  sludge data submitted to  the Agency  lacked EPA's protocol for
proper evaluation,  i.e., lacked paired influent (untreated) effluent
(treated)  data to determine treatability and therefore,  the data was not
used in the development  of treated  standards for K069 nonwastewaters.

    Congress has mandated  Land Ban  Restriction standards be based on BDAT
for treatment of waste.  Since the  BDAT  technologies can significantly
reduce the lead and cadmium levels, lead and cadmium treatment standards
will be developed.
                                     33
3557g-33

-------
    Since the process by which the K069 nonwastewater sludge  is  generated
closely resembles the process that generates the K061 nonwastewater  (both
are emission control dust/sludges), the Agency has no reason  to  believe
that the treatment levels achieved for cadmium and lead  in K061  cannot
also be achieved for K069.  Accordingly, EPA is using K061 performance
data to establish treatment standards for cadmium and lead in the  Calcium
Sulfate Subcategory of K069 nonwastewaters.

    The data presented for stabilization of K061 nonwastewaters  (see
Table 19) have been evaluated by EPA to ensure that any  data  representing
poor design and poor operation were deleted and that all data were
adjusted for analytical accuracy.  As a result, the data for  K061
stabilization were determined to represent treatment by  a well-designed
and well-operated treatment system.

    Table 23 presents the specific BDAT treatment standards for  K069
nonwastewater.  For the BDAT list metal constituents, treatment  standards
in nonwastewater reflect the concentration of constituents in the
leachate from the Toxicity Characteristic Leaching Procedure  (TCLP).  The
units for the leachate concentration are mg/1 (parts per million on a
weight-by-volume basis).   If the concentrations of the regulated
constituents in the K069, as determined in the leachate analytical
process, are lower than or equal to the concentration required in  the
BDAT treatment standards, then treatment is  not a prerequisite to  land
disposal.
                                    34
3557g-3<.

-------
3201g
         Table 20  Calculation of Corrected Values for Regulated Constituents
                                for Treated Wastewater
Constituent
Treated waste    Percent        Correction
  (mg/1)         recovery          factor
                           Corrected value
                                (mg/1)
Cadmium
Lead
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5
  <0.5

   0.17
   0.25
   0.25
   0.33
   0.17
   0.25
   0.33
   0.33
   0.33
   0.25
   0.33
   0.25
   0.33
   0.42
   0.33
 87"
                                                       1.15
115
i.o
-------
3201g
            Table 21   Calculation  of the  Treatment  Standards  for  the
                  Regulated Constituents - Treated Wastewater
Regulated
constituent
Cadmium
Lead
Cone.
<0.575
<0.575
<0.575
<0.575
<0.575
<0.575
<0.575
<0.575
<0.575
<0.575
0.17
0.25
0.25
0.33
0.17
0.25
0.33
0.33
0.33
0.25
0.33
0.25
0.33
0.42
0.33
Treatment standard
total concentration
Mean VF (mg/1)
0.575 2.8a 1.61
0.288 1.76 0.51
  For  cases  in which all values are at or below the detection limit, the
  variability factor is taken as 2.8.
                                         36

-------
SZOlg
             Table 22  BOAT Treatment Standards for K069 Wastes
                                (Wastewaters)
                                              Max 1 nun for any
                                            Single grab sample
                                            Total composition
Regulated constituent                           (mg/1)
Cadmium                                            1.61
Lead                                               0.51
                Table 23  BOAT Treatment Standards for K069
                        Calcium Sulfate Subcategory
                              (Nonwastewaters)
                                              Haximum for any
                                            Single grab sample
                                                 TCLP
Regulated constituent                           (mg/1)
Cadmium                                            0.14
Lead                                               0.24
                Table 24  BOAT Treatment Standards for K069
                          Non-Calcium Subcategory
                              (Nonwastewaters)
                      (Revised From No Land Disposal)
                 RECYCLING (LEAD) AS A METHOD OF TREATMENT

-------
REFERENCES

USEPA.  1977.  Draft.  Development Document for Effluent Limitations
  Guidelines and New Source Performance Standards for the Miscellaneous
  Nonferrous Metals Segment of the Nonferrous Metals Manufacturing Point
  Source Category.  Washington, D.C.:  U.S. Environmental Protection
  Agency.  440/1-76/067.

USEPA.  1986a.  U.S. Environmental Protection Agency.  Onsite engineering
  report of treatment technology performance and operation for Envirite
  Corporation.  Prepared by Versar Inc. for the Office of Solid Waste,
  U.S. Environmental Protection Agency, under Contract No. 68-01-7053.
  Washington, D.C.:  U.S. Environmental Protection Agency.

USEPA.  1987.  U.S. Environmental Protection Agency.  Onsite Engineering
  Report for Horsehead Resource Development Co., Inc. for K061.  Prepared
  by Versar Inc. for the Office of Solid Waste, U.S. Environmental
  Protection Agency, Contract No. 68-01-7053.   Washington, D.C.:  U.S.
  Environmental Protection Agency.

Morgan, Lewis, and Backius.   1988.  Philadelphia,  PA.  Letter to U.S.
  Environmental Protection Agency, Washington,  D.C., May 20,  1988, to
  Docket Regarding EPA's Proposed Land Disposal Restrictions for First
  Third of Scheduled Wastes, Docket No. LDR7000007.

USEPA.  1988a.  Final Best Demonstrated Available Technology (BOAT)
  Background Document for F006.  August 1988.   Washington, D.C.:  U.S.
  Environmental Protection Agency.  EPA/530-SW-88-031L.

USEPA.  1988b.  Final Best Demonstrated Available Technology (BOAT)
  Background Document for K062.  August 1988.   Washington, D.C., U.S.
  Environmental Protection Agency.  EPA/530-SW-88-031E.

USEPA.  1988c.  Final Best Demonstrated Available Technology (BOAT)
  Background Document for K061.  August 1988.   Washington, D.C., U.S.
  Environmental Protection Agency.  EPA/530-SW-88-031D.

USEPA.  1989.  U.S. Environmental Protection Agency, Office of Solid
  Waste.   Treatment Technology Background Document.   Washington, D.C.:
  U.S. Environmental Protection Agency.

USEPA.  1989.  U.S. Environmental Protection Agency, Office of Solid
  Waste.   Methodology Document; May 1989.   Washington, D.C.:   U.S.
  Environmental Protection Agency.

Tischler/Kocurek.   1989.   Public comment submitted in response to EPA
  proposed land disposal restrictions for Third Third Scheduled Wastes,
  February 27, 1990.  EPA RCRA Docket No.  LD12-L027.  Washington, D.C.:
  U.S. Environmental Protection Agency.
                                    38
3557g-38

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Exide Corporation.   1990.  Analytical  data  from  the  testing  of calcium
  sulfate sludge generated at  Exide's  Reading, Pennsylvania  Facility.
  Washington, D.C.:  U.S. Environmental  Protection Agency.   EPA (Docket)
  LD12-00117.
                                     39
3557g-39

-------
APPENDIX A

-------
                                 Appendix A




                       Tischler/Kocurek  Effluent  Data
Date
11/88





12/88

1/89





2/89







4/89



5/89




Lead (mg/1) Date
2.0 6/89
0.1
0.3
0.1
0.1
7/89
0.2
0.2
0.3 8/89
0.7
0.2
0.2
0.4
9/89
0.4
0.4
0.2
10/89
0.6
0.3
0.4

0.2
0.3 11/89
0.3
0.3
0.3
0.2
0.1
0.4
0.3
Lead (mg/1)
0.4
0.3
0.4
0.4

0.2
<0.001

0.2
0.2
0.6
0.4

0.3
0.4
0.4

0.3
0.4
0.2
0.4
0.2

0.1
0.2
0.2





Reference:  Tischler/Kocurek (LD12-00027)

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