United States
Environmer.tal Protection
Agency
Office of Water Regulations
and Standards
EPA 44C 1 89 1 CO
September 1989
Preliminary Data
Summary  for the
Hazardous Waste
Treatment Industry

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           PRELIMINARY DATA SUMMARY

                    FOR  THE

      HAZARDOUS WASTE TREATMENT INDUSTRY
  Office of Water Regulations and Standards
               Office of Water
United States Environmental Protection Agency
               Washington,  D.C.

                September 1989

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                             PREFACE


     This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency.  The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges.  The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.

     The Summaries vary in terms of the amount and nature of the
data presented.  This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry.  With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries.  This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking.  Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.

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                         ACKNOWLEDGEMENTS


Preparation of this Preliminary Data Summary was directed by
Donald F. Anderson, Project Officer, of the Industrial Technology
Division.  Joseph Yance, Analysis and Evaluation Division, and
Alexandra Tarnay, Assessment and Watershed Protection Division,
were responsible for preparation of the economic and
environmental assessment analyses, respectively.  Support was
provided under EPA Contract Nos. 68-03-3509, 68-03-3366, and 68-
03-3339.

Additional copies of this document may be obtained by writing to
the following address:

          Industrial Technology Division  (WH-552)
          U.S. Environmental Protection Agency
          401 M Street,  S.W.
          Washington,  D.C. 20460

          Telephone  (202) 382-7131

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                             TABLE  OF  CONTENTS


                                                                     PAGE

1 •   FOREWORD  	                -L


2.   SUMMARY  	   2


3.   INTRODUCTION  	  10

     3.1   SUMMARY  OF HAZARDOUS WASTE  REGULATIONS  	  10

           3.1.1  Regulation of Hazardous  and Solid  Waste  Landfills...  12
           3.1.2  Regulation of Hazardous  Waste  and  PCB  Incinerators  .  14
           3.1.3  Regulation of Commercial Aqueous Waste Treatment
                 Facilities 	  15

     3 .2   DISCUSSION OF WQA REQUIREMENTS  	  16

           3.2.1  Regulation of Direct Discharges to Surface Water  ...  16
           3.2.2  Regulation of Indirect Discharges  to
                 Publicly-Owned Treatment Works 	  18

     3 . 3   INDUSTRY GROWTH POTENTIAL 	  19


4.   HWT INDUSTRY  PROFILE 	  20

     4.1   DEFINITIONS OF THE HWT INDUSTRY 	  21
     4.2   DESCRIPTION OF THE HWT INDUSTRY 	  21

           4.2.1  Landfills and Leachate Collection  and  Treatment ....  22
           4.2.2  Incinerators and  Scrubber Wastewater  	  23
           4.2.3  Aqueous Hazardous Waste  Treaters  	  24
           4.2.4  Integrated Facilities 	  25

     4.3   NUMBER OF HWT FACILITIES 	  26

           4.3.1  Landfills 	  26
           4.3.2  Incinerators and  Scrubbers 	  31
           4.3.3  Aqueous Hazardous Waste  Treaters  	  35

     4.4   GEOGRAPHIC DISTRIBUTION  OF  THE  HWT INDUSTRY  	  38
     4.5   HWT  INDUSTRY SIZE ESTIMATE  SUMMARY 	  38
     4.6   FINANCIAL CHARACTERISTICS OF COMMERCIAL FACILITIES  	  38
     4.7   COMMERCIAL HAZARDOUS WASTE  MANAGEMENT PRICE  	  41
     4.8   SUMMARY  	  41

5.    RAW WASTE CHARACTERIZATION 	  45

     5.1   POLLUTANT ANALYSIS,  RECOVERY, AND QUANTIFICATION  	  45

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                 TABLE OF CONTENTS (Continued)


                                                                 PAGE

5.2  LEACHATE 	   47

     5.2.1  Sources of Raw Data 	   47
     5.2.2  Pollutants in the Raw Leachate 	   48

            5.2.2.1  Conventional and Nonconventional Pollutants  48
            5.2.2.2  Toxic Pollutants 	   57

     5.2.3  Leachate Flow Generation Rates 	   71
     5.2.4  Summary 	   71

5.3  INCINERATOR SCRUBBER WASTEWATERS 	   75

     5.3.1  Sources of Incinerator Scrubber Wastewater Data  ....   75
     5.3.2  Pollutants in the Incinerator Scrubber Wastewaters  .   75

            5.3.2.1  Conventional and Nonconventional Pollutants  75
            5.3.2.2  Toxic Pollutants 	   76

     5.3.3  Scrubber Wastewater Flow Rates 	   80
     5.3.4  Summary 	   83

5.4  AQUEOUS HAZARDOUS WASTE 	   83

     5.4.1  Sources of Raw Waste Data 	   83
     5.4.2  Pollutants in the Raw Aqueous Hazardous Waste  	   84

            5.4.2.1  Conventional and Nonconventional Pollutants  84
            5.4.2.2  Toxic Pollutants 	   84

     5.4.3  Aqueous Hazardous Waste Flow Rates  	   88
     5.4.4  Summary 	   88

CONTROL AND TREATMENT TECHNOLOGIES 	   93

6.1  LEACHATE TREATMENT 	   93

     6.1.1  Sources of Data 	   93
     6.1.2  Subtitle D and Subtitle C Facilities  	   94
     6.1.3  Preliminary Treatment 	   94

            6.1.3.1  Treated Effluent Data 	   94
            6.1.3.2  Residuals Data 	   97

     6.1.4  Biological Treatment 	   97

            6.1.4.1  Treated Effluent Data 	   97
            6.1.4.2  Residuals Data 	   99

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                      TABLE  OF  CONTENTS  (Continued)


                                                                     PAGE

          6.1.5  Advanced  Treatment  	 103

                 6.1.5.1   Treated  Effluent  Data  	 103
                 6.1.5.2   Residuals  Data  	 106

          6.1.6  Other  Control  and Treatment Technologies  	 106
          6.1.7  Summary  	 108

     6.2  SCRUBBER WASTEWATER TREATMENT  	 108

          6.2.1  Sources of  Data  	 108
          6.2.2  TSCA Versus RCRA  Facilities  	 109
          6.2.3  Physical/Chemical Treatment  	 109

                 6.2.3.1   Treated  Effluent  Data  	 109
                 6.2.3.2   Residuals  Data  	 112

          6.2.4  Advanced  Treatment  	 112

                 6.2.4.1   Treated  Effluent  Data  	 114
                 6.2.4.2   Residuals  Data  	 117

          6.2.5  Other  Treatment and Disposal Methods  	 117
          6.2.6  Summary of  Scrubber Wastewater  Treatment  	 120

     6.3  AQUEOUS HAZARDOUS  WASTE  TREATMENT 	 120

          6.3.1  Sources of  Data  	 121
          6.3.2  Physical/Chemical Treatment  	 121

                 6.3.2.1   Treated  Effluent  Data  	 121
                 6.3.2.2   Residuals  Data  	 125

          6.3.3  Advanced  Treatment  	 128

                 6.3.3.1   Treated  Effluent  Data  	 128
                 6.3.3.2   Residuals  Data  	 132

          6.3.4  Conclusions 	 134


7.    COST OF WASTEWATER CONTROL AND  TREATMENT 	 136

     7.1  AQUEOUS TREATERS SUBCATEGORY  	 139
     7.2  LEACHATE TREATMENT SUBCATEGORY  	 139
     7!3  SCRUBBER WASTEWATER SUBCATEGORY 	 146

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                 TABLE OF CONTENTS  (Continued)
7.4  ECONOMIC ASSESSMENT AND  COST  EFFECTIVENESS 	 146

     7.4.1  Preliminary Economic Impact Assessment 	 146
     7.4.2  Cost-Effectiveness  	 150

            7.4.2.1  Scrubber Wastewater Systems 	 150
            7.4.2.2  Leachate Treatment Systems 	 152
            7.4.2.3  Aqueous  Hazardous  Waste Treaters 	 152

7 . 5  SUMMARY  	 158


ENVIRONMENTAL ASSESSMENT  	 159

8 . 1  METHODOLOGY  	 159

     8.1.1  Direct Discharge  Analysis  	 159
     8.1.2  Indirect Discharge  Analysis 	 160

8.2  RESULTS OF ENVIRONMENTAL ASSESSMENT 	 160

     8.2.1  Landfill Leachate Subcategory 	 160

            8.2.1.1  Direct Dischargers 	 160
            8.2.1.2  Indirect Dischargers 	 162

     8.2.2  Scrubber Wastewater Subcategory 	 164

            8.2.2.1  Direct Dischargers 	 164
            8.2.2.2  Indirect Dischargers 	 165

     8.2.3  Aqueous Hazardous Waste  Subcategory 	 167

            8.2.3.1  Direct Dischargers 	 167
            8.2.3.2  Indirect Dischargers 	 168

8.3  NON-WATER QUALITY ENVIRONMENTAL ASPECTS 	 170

     8.3.1  Air Pollution  	 170
     8.3.2  Solid Waste 	 171
     8.3.3  Energy Requirements 	 171


REFERENCES 	 172

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                              LIST OF TABLES


TABLE
                                                                     PAGE
4 1    Estimates  of  the  Number  of Hazardous Waste and
       Subtitle D Landfills  	  27

4-2    Leachate Management at Subtitle D Landfills  	  29

4-3    Leachate Treatment/Disposal  Practices - Summary
       of Available  Data 	  30

4-4    Estimate of the Number of Hazardous Waste Incinerators 	  32

4-5    Management of Incinerator Scrubber Wastewater -
       Summary of Available  Data  	  34

4-6    Estimates  of  the  Number  of Agueous Hazardous Waste Treaters ..  36

4-7    Disposal of Wastewaters  by Facilities Managing Agueous Hazardous
       Wastes - Summary  of Available Data 	  37

4-8    HWT  Industry  Profile  	  39

4-9    Statistics of Selected Financial Ratios for the HWT Industry  .  40

4-10   Statistics of Selected Financial Ratios for the Selected Firms
       in the HWT Industry  	  42

4-11   Comparison of Hazardous  Waste Management Prices (per Gallon)
       Quoted by  all Firms in 1983, and 1985a/ 	  43

5-1    Contaminant Concentration Ranges in Leachate Reported in the
       Literature	  49

5-2    Conventional  and  Nonconventional Pollutants and Metals Summary
       in Raw Leachate - HWT Study  Sampling Results 	  50

5-3    Overall Summary from  the Analysis of Municipal Solid Waste
       Leachates  in  Wisconsin 	  52

5-4    Most Commonly Occurring  Conventionals, Nonconventionals, and
       Metals in  Leachate Samples - CLP Database, 1980-1983 Data ....  53

5-5    Conventional  and  Nonconventional Pollutants and Metals in
       Miscellaneous Subtitle D Landfill Leachates  	  54

5-6    Pollutants  in Hazardous  Waste Landfill Leachates -
       ORD/HWERL  Study 	  55

5-7    Pollutants  in Hazardous  Waste (Subtitle C) Landfill
       Leachates  - NEIC  Study 	  56

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                        LIST  OF TABLES (Continued)


TABLE

5-8    Organic Compounds Found  in Raw Leachate  	   58

5-9    Organic Compounds Found  in Raw Leachate
       Composite of Data Sources 	   65

5-10   Most Frequently  Found Organic Compounds  in Leachates  	   70

5-11   Organic Compounds Found  at the Highest Concentrations
       in Leachate  	   72

5-12   Leachate Generation, Wisconsin Study  	   73

5-13   Conventional and Nonconventional Pollutants  in Raw Scrubber
       Wastewaters  	   77

5-14   Metals  in Raw  Scrubber  Wastewater  	   78

5-15   Organics in  Raw  Scrubber Wastewater  	   79

5-16   Scrubber Wastewater Slowdown Rates  	   81

5-17   Summary of Hazardous  Waste Incinerator Types and  Capacities ..   82

5-18   Conventional and Nonconventional Pollutants  in
       Aqueous Hazardous Wastes - Summary  	   85

5-19   Metals  in Aqueous Hazardous Wastes  -  Summary 	   86

5-20   Pollutants in  Aqueous Hazardous Wastes - Summary  	   89

6-1    Concentrations of Pollutants in Preliminary  Treatment System
        (Aerated Lagoon) Effluents - Leachate Subcategory 	   95

6-2    Concentrations of Pollutants in Preliminary  Treatment System
       Sludge  - Leachate Subcategory  	   98

6-3    Concentrations of Pollutants in Biological Treatment  System
       Effluents -  Leachate  Subcategory  	  100

6-4    Concentrations of Pollutants in Biological Treatment  System
       Sludge  - Leachate Subcategory  	  102

6-5    Concentrations of Pollutants in Advanced Treatment System
       Effluents -  Leachate  Subcategory  	  104

6-6    Concentrations of Selected Pollutants in Advanced Treatment
       System  Sludges - Leachate Subcategory 	  107

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                        LIST OF TABLES (Continued)


TABLE
                                                                     PAGE
6 7    Concentrations of Pollutants in Physical/Chemical Treatment
       System Effluents - Scrubber Wastewater Subcategory 	 110

6-8    Concentrations of Pollutants in Physical/Chemical Treatment
       System Sludges - Scrubber Wastewater Subcategory 	 113

6-9    Concentrations of Pollutants in Advanced Treatment System
       Effluents  - Scrubber Wastewater Subcategory 	 115

6-10   Concentrations of Pollutants in Advanced Treatment System
       Sludges -  Scrubber Wastewater Subcategory 	 118

6-11   Concentrations of Pollutants in Physical/Chemical Treatment
       Systems -  Aqueous Treaters Subcategory	 122

6-12   Concentrations of Pollutants in Physical/Chemical Treatment
       System Sludges - Aqueous Treaters Subcategory 	 126

6-13   Concentrations of Pollutants in Advanced Treatment System
       Effluents  - Aqueous Treaters Subcategory 	 129

6-14   Concentrations of Pollutants in Advanced Treatment System
       Sludges -  Aqueous Treaters Subcategory 	 133

7-1    Design Basis  for Treatment System Cost Estimates 	 137

7-2    Model Aqueous Treatment System Costs 	 143

7-3    Model Leachate Treatment System Costs 	 144

7-4    Model Scrubber Treatment System Costs 	 145

7-5    Model Facilities and Costing 	 147

7-6    Model Plants of Hazardous Waste Treatment Facilities and
       Control Cost to Revenue Comparison  	 149

7-7    Cost-Effectiveness Calculation for  Scrubber Wastewater
       Treatment  Systems 	 151

7-8    Cost-Effectiveness Calculation for  Leachate Treatment Systems  153

7-9    Cost-Effectiveness Calculation for  Aqueous Treatment Systems  . 156

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                             LIST OF FIGURES
                                                                     PAGE
5-1    Leachate Flow Rates in Wisconsin .............................   74



7-1    Model Aqueous Waste Treatment System .........................  140



7-2    Model Leachate Treatment System ..............................  141



7-3    Model Scrubber Wastewater Treatment System ...................  142

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                           1.   FOREWORD


     The  Industrial   Technology   Division  (ITD)   of  the  U.S.
Environmental Protection Agency (EPA) has conducted a study of  the
hazardous waste  treatment  industry as  a result of findings  from
the  Domestic Sewage  Study.   The  purpose of  this  study  is  to
develop information to characterize the hazardous waste treatment
industry  as to  the  scope  of  the industry,  its  operations,  its
dischargers  to  the  Nation's  waters,  and  identification  and
quantification  of  the  pollutants  discharged to  the  Nation's
waters.

     The Agency  collected  data and information from a variety of
sources  from  which  conclusions   were  drawn.    The  information
gathering efforts  of the Agency  were  supplemented  by efforts of
the Office  of Research and  Development  (ORD), the Office of Solid
Waste  (OSW),  local  governments,   and  the  states.    Wastewater
sampling  was conducted  at twelve  sites  and the  data  collected
represent the  best  available  for characterizing the  industry.
Analyses    were   conducted    for   over   400    conventional,
nonconventional, priority,  and Resource Conservation and Recovery
Act  (RCRA)  pollutants.

     Since  this report was initially prepared, the Office of Water
Regulations and Standards has continued to obtain information about
the  industry,  particularly through analysis  of responses to the
National Survey  of Hazardous  Waste Treatment, Storage,  Disposal,
and Recycling  (TSDR)  Facilities  conducted by the U.S. EPA Office
of Solid Waste.  The TSDR Survey data  provides a  good deal of new
information on wastewater  treatment and the other processes used
to manage hazardous waste,  including counts of facilities carrying
out the various hazardous waste management processes and data for
the  volume  of  liquid  residuals.    As  this new  material  is
considered,  the  scope of  the Agency's   rulemaking  efforts  for
hazardous waste treatment  facilities will  be  determined.

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                      2.  SUMMARY
The hazardous waste treatment (HWT)  industry was divided into
three subcategories:


     Landfills  with   leachate  collection  and  treatment
     facilities

     Incinerators with wet scrubbers

     Aqueous hazardous waste treaters


The number  of  facilities in each  subcategory was estimated
as follows:


          Subcategory                 Number of Facilities

Landfills with leachate systems                911
Incinerators with wet scrubbers                273
Aqueous hazardous waste treaters               725
The  most  common  method  of  wastewater  disposal   for  the
landfill and  aqueous hazardous waste  treater subcategories
was  indirect  discharge  to  Publicly-Owned Treatment Works
(POTWs).   Incinerators  with scrubbers  were  more   commonly
direct dischargers.   The  breakdown of each  subcategory by
discharge method was estimated to be:
                              Number of Facilities
                       Direct       Indirect       Other

Leachate                 173           355          383
Wet Scrubbers            137            27          109
Aqueous Treaters          87           515          123
Other discharge included  deep  well injection, incineration,
off-site disposal, land application,  and solidification and
reburial.

EPA Regions  V and VI  had the  largest  number  of hazardous
waste landfills  and incinerators.    The largest  number of
aqueous  waste treatment facilities were  in EPA Region V.

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Observations made concerning raw landfill leachates include:

     Some  leachates   contained  very  high  concentrations
     (>100,000 jug/1) of toxic organic compounds.

     The  analytical methods used to identify  and  quantify
     organic  pollutants  in leachate may have  a significant
     effect  on which  organics  are identified  and on  the
     concentrations found.

     Raw leachates were characterized by high concentrations
     of BOD5, COD, and TOC.

     Volatile  organics frequently were  found  in leachates,
     while non-volatile compounds may be present but were not
     readily detected.

     Hazardous waste  landfill  leachates appeared to contain
     more toxic organic compounds than leachate  from Subtitle
     D landfills, but this observation may  be due to the list
     of analytes and/or analytical methodology problems.  In
     terms of COD and TOC,  however, there  was no  apparent
     difference  between  hazardous  waste   and  Subtitle  D
     landfills.

-    Leachate flow rates varied  widely due in part to climatic
     and geological conditions,  but were not related to the
     size of  the  landfill.   Leachate flowrate was estimated
     to  be 30,000  gpd for  an  "average"  landfill  and  the
     reported range of flow was  0 to 94,000  gpd.

     Leachates  generally  contained  high  concentrations  of
     aluminum,   iron,   manganese,  and  boron,   while  the
     concentrations  of   toxic   metals   varied  from  below
     detection to over 100 mg/1.

     Leachates  from hazardous  waste landfills  appeared  to
     contain  higher  concentrations  of toxic   metals  than
     leachate from Subtitle D landfills.

Raw wastewaters from the  incinerator wet scrubber subcategory
were characterized as  follows:

     Chemical characteristics of raw scrubber wastewaters were
     a  function of the  scrubber system  operation.   High
     ammonia  concentrations  were found  in  systems  that use
     ammonia  to  neutralize acids.   TSS concentrations were
     high in systems that did not use lime precipitation.

     Raw scrubber wastewaters were  characterized by low pH,
     high TDS, and high chlorides.

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     Scrubber wastewaters  contained high  concentrations of
     metals.      The   metals   detected   at   the   highest
     concentrations  include  aluminum,  iron,  lead,  zinc,
     mercury, and copper.

     Scrubber  wastewaters   contained   very  few   organic
     pollutants.

     The   average   scrubber   wastewater   discharge   was
     approximately 93,000  gpd, although flowrates could range
     as high as 350,000 gpd.

Observations regarding the pollutants in raw aqueous hazardous
wastes were as follows:

-    Aqueous hazardous wastes contained high concentrations
     of BOD5, COD, and TOC.

     Both metal  and  organic compounds were found  in a wide
     range of concentrations and,  in some cases, at very high
     concentrations.

     The organics  found most frequently and  at  the highest
     concentrations were industrial solvents  (e.g., acetone,
     2-butanone, methylene chloride, benzene, and toluene).

     The metals found at the highest concentrations and most
     frequently  were  chromium,  copper, nickel,  zinc,  iron,
     aluminum, boron, and manganese.

     The wide range of concentrations of the toxic pollutants
     in the  raw  waste  samples can be attributed to the high
     variability  of  wastes  received  and  treated  by  these
     facilities.

     Flowrates at facilities treating aqueous  hazardous waste
     averaged 45,500  gpd  and ranged  from  13,600  to 117,000
     gpd.

A  wide range  of  treatment technologies  was employed  for
leachate  treatment,    including   treatment  and  discharge,
recirculation,   solidification   and   reburial,   deep  well
injection,  and contract hauling.

Advanced leachate treatment systems that involved biological
treatment and physical/chemical effluent polishing processes
were capable of  achieving up to  90 percent removal of BOD5_,
COD, TOC,  ammonia,  and  TKN.   These systems had achieved
effluent BOD5. concentrations of  10 mg/1 or less.   Even with
advanced  treatment   systems,    iron  and   boron  effluent
concentrations average over 1,000 Mg/1-    Treated leachate
concentrations of other toxic metals were  usually below 500

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Mg/1,  frequently less  than 100  pg/1.    Significant  metals
removal occurred during the biological treatment process,  as
evidenced  by  the elevated  concentrations of metals  in  the
sludges.   The metals  with the  highest concentrations  in  the
sludges  were those  with high  concentrations  in  the  raw
leachate  (i.e.,  iron,  manganese,  aluminum).   Boron,  whose
concentrations   were   frequently  high   in   raw  leachate,
demonstrated  relatively  poor  removal  with high  effluent
concentrations and  relatively low sludge concentrations.

Scrubber   wastewater  treatment   systems   consisted   of
technologies designed for the removal of  inorganic pollutants.
Chemical precipitation/sedimentation provided metals removal,
and  filtration and  carbon adsorption were used if necessary
to polish  portions  of the  effluents  to meet permit limits.
Consequently, no significant reduction  in COD occurred,  but
effluent  concentrations  were  relatively  low.   Even  with
advanced   treatment,    effluent   concentrations  of   iron,
manganese, boron, molybdenum,  and zinc were above 1,000 M9/1-
Effluent concentrations of the heavy metals were below  100
In addition to treatment and disposal systems, other methods
of   scrubber   wastewater   disposal   included   landfill,
evaporation, and contract hauling.

Scrubber wastewater treatment system sludges were  found to
contain  a  large  number  of dioxin/furan  isomers,   some at
extremely high concentrations.  Dioxins/furans were relatively
insoluble  in  water and tended to  adsorb  onto particulates.
Although the treatment system effluents  were  not analyzed for
dioxins/furans, these compounds may be discharged to POTWs or
surface waters by way of the suspended  solids in the treated
effluents.  Further analysis of  treated effluents is needed
to  determine   if  the treatment  technologies  in-place  were
effectively removing dioxins/furans.

Aqueous  hazardous   waste   treatment  systems  ranged   from
precipitation/sedimentation  units  to advanced secondary and
tertiary systems.

Precipitation/sedimentation units  at  aqueous hazardous waste
treaters achieve large  reductions  in heavy metals;  however,
toxic organics receive limited treatment and  pass through the
treatment system.

Advanced treatment systems at aqueous hazardous waste treaters
are more  effective in  removing  organic compounds;  however,
high effluent concentrations of  organic compounds are common
even with  advanced  treatment.   This conclusion is supported
by high effluent concentrations  of indicator pollutants  such
as  BOD5, TOC, and  COD, which show relatively poor removals.

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     The relatively  poor removal  of  TOC and  BOD5 by  advanced
     treatment systems  employing   biological  treatment  and/or
     carbon adsorption indicates the potential  for discharges of
     poorly treated hazardous wastes to POTWs or surface waters.
     Advanced  treatment  systems  demonstrated  metals  removal
     efficiencies and  effluent concentrations  similar  to  those
     achieved by  physical/chemical  treatment systems.

     Many  of  the toxic  organic pollutants  accepted by aqueous
     hazardous waste  treatment  facilities  are not  effectively
     removed by physical/chemical or advanced treatment systems.
     Effluent concentrations of individual  organic compounds can
     exceed 10,000 M9/1/ even with advanced treatment technologies,
     such  as  carbon adsorption.   Biological  treatment  is  also
     relatively  ineffective in  the treatment   of some  organic
     compounds.

     High  concentrations of a  large number  of isomers  were found
     in the treatment sludges of aqueous waste treaters.  However,
     the effluent  samples  were not  tested for   dioxins/furans.
     Dioxins/furans are relatively insoluble in  water and tend to
     adsorb on particulates.  High effluent TSS concentrations were
     found  from  both  physical/chemical  and advanced  treatment
     systems, which indicates  the potential  for the discharge of
     these  isomers.   Sampling and testing  of   treatment  system
     effluents for  dioxins/furans  is necessary  to establish the
     concentrations of these compounds  in  treated effluent and the
     effectiveness of various treatment systems  for their removal.


     Treatment costs were developed based on treatment technologies
     that  correspond  to  common,   typically  sized,  facilities
     operating in the HWT industry.  Cost estimate developed for
     a typically sized facility in  each subcategory are:

                                      Operating  Cost,   Annualized
Subcategory           Investment. $   	$/yr	   Cost.  $/yr

Leachate Treatment        806,000          286,000         542,500
Scrubber Wastewater     1,501,000          381,000         854,300
Aqueous Treaters           767,000          325,000         569,600


     Leachate treatment could increase  municipal landfill tipping
     fees.

     Implementation of the model wastewater treatment technologies
     would  result in a net decrease in air emissions and increases
     in the amount of solid wastes  generated and energy consumed.
     Air emissions potentially could be reduced by 39.6 million
     pounds of volatile pollutants  per  year.   The    amount of
     additional sludge generated could be as high as 380,000 metric

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                                                     *•
     tons per year.  The amount of increased energy consumed as a
     result of possible regulations could total 91,000 barrels of
     No. 2 fuel per year.  These conservative estimates assume that
     no treatment  is currently in-place.

     The  cost  of implementing the model  technologies  was modest
     compared  to  average  revenues for  the HWT  industry-   The
     average incinerator would be required to increase revenues by
     4.7 percent to cover control costs.   A  municipal landfill and
     hazardous waste landfill would increase tipping fees by 35.5
     and  3.8 percent,  respectively.   An aqueous treater would be
     required to increase revenues by  3.0  percent to cover control
     costs.

     The  toxic organic raw waste loads and  metals raw waste loads
     for each subcategory, based on the  total number of facilities
     in each subcategory, were estimated to be:

                             	Raw Waste Load, Ib/vear	
Subcategory                 Total Toxic Organic      Total Metals

Leachate                         50,090,000           35,500,000
Wet Scrubbers                       353,000           26,940,000
Aqueous Treaters                 23,680,000          406,150,000


     The raw waste  loads for the regulated community (direct and
     indirect discharges only) were estimated to be:

                                           Raw Waste Load. Ib/yr
                    No.  of Facilities   Total Toxic
Subcategory         Direct   Indirect     Orqanics   Total Metals

Leachate             173       355       29,030,000    20,580,000
Wet Scrubbers        137         27          212,000    16,180,000
Aqueous Treaters      87       515       19,660,000   337,250,000


     Environmental  impacts  of  the  leachate subcategory,  based on
     the combined data base from six independent  studies,  found of
     the total  215  pollutants detected, 111  were  at levels that
     may  be  harmful  to human  health  and/or  aquatic   life  if
     discharged untreated  directly into surface waters.   Of the
     111  pollutants  (with  exceedances),   70  would  exceed human
     health criteria  (41 for  carcinogenicity protection, 29 for
     toxicity protection),  39 would exceed  acute  or short-term
     aquatic criteria/toxicity levels, and 87  would  exceed chronic
     or long-term aquatic criteria/toxicity levels.  In addition,
     32   pollutants   in   untreated   leachates   would   exceed
     existing/proposed EPA drinking water criteria.   Most  of these
     111  pollutants  have   both  human  health  and  aquatic  life
     impacts.

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Indirect discharges of untreated leachates,  based on projected
discharge to a model  1 MGD POTW, may cause  POTWs to exceed
human health  criteria for  24 pollutants  (23  of  these are
carcinogens) ,  drinking water  criteria for  2  pollutants, and
acute and chronic aquatic criteria/toxicity levels for 7 and
10 pollutants,  respectively-  In addition,  4  pollutants may
have detrimental impacts on POTWs  (4  causing POTW treatment
inhibition,  1   causing  sludge   contamination  problems).
However, this analysis was  based on limited POTW inhibition
data and sludge criteria.

Environmental  impacts  of  the  scrubber  subcategory  were
evaluated  using  1986-1987 EPA-ITD sampling   data.    This
subcategory  discharges  30 pollutants,  of  which  27  were
detected  at levels that  would be  harmful to  human  health
and/or  aquatic  life  if  discharged untreated  directly into
surface waters.   Of these 30 pollutants,  13  would exceed human
health criteria (5  for carcinogenicity protection,  8 for human
toxicity  protection) ,  9  pollutants would exceed acute  or
short-term aquatic criteria/toxicity levels.  In addition, 11
pollutants  in untreated wastewaters are discharged at levels
projected  to exceed  EPA  existing/proposed  drinking  water
criteria.   Most of the  27 pollutants with  exceedances are
projected to impact both human health and aquatic life.

Indirect  discharges   of   untreated  wastewater,   based  on
projected discharge to a model 1  MGD POTW,  may cause POTWs to
exceed human health criteria  for 3  pollutants  and acute and
chronic  aquatic  criteria  toxicity  levels  for  6  and  7
pollutants, respectively.   Six pollutants  were projected to
have detrimental impacts on POTWs (4 may cause inhibition, 6
may  cause  sludge contamination problems),  based  on  limited
inhibition data and sludge criteria.

The  environmental  impacts  of  the aqueous subcategory,  based
on data from both the EPA-ITD and OSW studies, found the total
number of pollutants with exceedances, as well as the number
of   human   health,  drinking   water,   and/or  aquatic  life
exceedances for most of the pollutants,  projected for direct
discharges  of  untreated  wastewater  was  55.   Of these  55
pollutants, 31  would  exceed  human  health  criteria  (21 for
carcinogenicity protection, 10 for  toxicity  protection),  22
would exceed existing/proposed EPA  drinking  water criteria,
17   would  exceed  acute   or  short-term   aquatic   life
criteria/toxicity  levels,  and  36   would  exceed  chronic  or
long-term aquatic life criteria/toxicity levels.

Indirect  discharges  of untreated  wastewater,  based  upon
projected discharge to a model 1  MGD POTW,  may cause POTWs to
exceed  human  health  criteria  for  12   pollutants   (10  for
carcinogenicity    protection),     acute    aquatic    life

                              8

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criteria/toxicity  levels for 7  pollutants,  chronic aquatic
life criteria/ toxicity levels for 10 pollutants,  and drinking
water criteria  for 4 pollutants in their receiving streams.
In addition,  six pollutants may have detrimental impacts on
POTWs (6 causing POTW  treatment  inhibition, 6 causing sludge
contamination problems).

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                         3.   INTRODUCTION
     The  study  of hazardous waste treatment  facilities is being
conducted  by the United  States Environmental  Protection Agency
(USEPA)  with assistance from  Science  Applications International
Corporation  (SAIC) under Contract No. 68-03-5309.  The purpose of
the study was to develop information  to characterize the hazardous
waste treatment  (HWT) industry's scope, operations, and discharge
to the Nation's waters,  and to identify and quantify the pollutants
in the discharge.

     This  study  of the  HWT industry was conducted under authority
of  Sections 301, 304, 306,  307,  308, and  501  of the Water Quality
Act  (WQA).  In  addition  to regulations  for  designated industry
categories,  Section  307(a)  of  the WQA required  promulgation of
effluent   standards   applicable  to  all   dischargers  of  toxic
pollutants.

For the purposes of this study, the HWT industry has been defined
as follows:
          Landfills   with  leachate  collection   and  treatment
          facilities.   In this  study,  the term leachate was used
          to describe all aqueous discharges from  landfills.  This
          discharge can include both leachates collected from the
          bottom of the landfill and any groundwater recovered at
          the site.

          Incinerators with wet scrubbers.

          Aqueous hazardous waste treaters.
3.1  SUMMARY OF HAZARDOUS WASTE REGULATIONS

     Subtitle  C of  the Resource  Conservation and  Recovery Act
(RCRA)  of 1976 directed EPA to promulgate regulations to protect
human health and the  environment  from the improper management of
hazardous wastes.   Based on this  statutory  mandate,  the goal of
the RCRA  program is to  provide  comprehensive, "cradle-to-grave"
management of hazardous  waste.   Key statutory provisions in RCRA
Subtitle C include:


          Section 3001 - requiring the promulgation of regulations
                         identifying   the   characteristics   of
                         hazardous  waste  and  listing particular
                         hazardous wastes

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           Section 3002  - requiring the promulgation of  standards
                          (e.g.,  manifesting, recordkeeping, etc.
                          applicable to  generators  of  hazardous
                          wastes

           Section 3003  - requiring the promulgation of  standards
                          (e.g.,  manifesting,  recordkeeping, etc.)
                          applicable to transporters of  hazardous
                          wastes

           Section 3004  - requiring the promulgation of performance
                          standards applicable to  the owners and
                          operators   of   facilities    for   the
                          treatment,  storage,   or  disposal  of
                          hazardous wastes

           Section 3005  - requiring the promulgation of regulations
                          requiring each person owning or operating
                          a  treatment,   storage,    or  disposal
                          facility (TSDF) to obtain a permit  issued
                          pursuant to Section 3005.

In 1980, EPA began promulgating regulations to implement these and
other  statutory directives contained in  RCRA.

     Under RCRA,  waste  management  requirements   are  initially
triggered  by a determination that a waste is hazardous as defined
in RCRA hazardous waste identification and listing  regulations (40
CFR Part 261).   Any  party producing a  hazardous  waste  is termed a
generator  under RCRA.   A generator must provide notification to
EPA  and   obtain  an  EPA  identification   number.     Subsequent
transportation,  treatment, storage, or disposal of the  wastes is
subject   to  waste   tracking   requirements  (i.e.,   manifesting
requirements)  and numerous other  management requirements under
RCRA.  Any party, including the  original generator, that treats,
stores,  or  disposes  of  a hazardous  waste  also  must provide
notification to EPA and obtain  an EPA identification number.  These
facilities,  typically  referred  to as  treatment,  storage,  and
disposal   facilities  (TSDFs),   are subject to  extensive RCRA
performance standards pertaining to the management of these wastes.
Existing RCRA regulations contain performance standards for various
types  of treatment,  storage, and disposal  (TSD)  units,  including
containers,  tanks,  surface  impoundments,  waste    piles, land
treatment  units,  landfills, and incinerators (40 CFR Parts  264 and
265) .  Moreover,  TSDFs are required to obtain RCRA  permits, known
as Part B  permits, to ensure their compliance with all applicable
performance standards.  Where a hazardous waste is transported off-
site from a generator's  premises,  the transporter also is regulated
by the hazardous  waste management system and  must comply with
manifesting requirements to ensure delivery of the  hazardous waste
to an  approved  TSDF.
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      In interpreting relevant statutory provisions of RCRA, EPA has
granted broad exemptions from RCRA requirements  in areas  relating
to  wastewater management.    The three key wastewater  exemptions
include:

           Domestic  sewage exclusion -  excludes from regulation as
           either a solid or  hazardous waste any mixture of  domestic
           sewage  and other wastes that  passes through  a  sewer
           system to a POTW for treatment.   Based  on current Agency
           interpretation, the exemption begins when the waste first
           enters  a sewer system  that  will mix  it  with  sanitary
           wastes prior  to POTW  storage or  treatment,  but  does not
           exclude' industrial  wastewaters  while they  are  being
           collected,  stored,  or treated prior to  discharge  to  a
           POTW.

           Direct discharge exclusion - excludes from regulation as
           either   a   solid  or  hazardous  waste any  industrial
           wastewater  dischargers that are point source dischargers
           subject  to  regulation  under WQA Section   402.    This
           exemption begins when the wastewater  is first discharged
           to  surface  waters,   but  does  not  exclude  industrial
           wastewaters while they  are  being collected,  stored,  or
           treated  prior to  discharge to surface  waters.

           Wastewater  treatment  exemption  -   exempts  wastewater
           treatment  units  from TSDF  performance standards  and
           permitting  requirements.  A wastewater  treatment unit is
           defined  as  a device that  is  part  of  a  wastewater
           treatment   facility  subject  to   regulation  under  WQA
           Sections  402(a)  or   307(b); treats  or stores  influent
           wastewaters  or wastewater  treatment  sludges that  are
           hazardous; and meets the definition of  tank  contained in
           40  CFR  Part  260.   The term  "tank"  is  defined  as  a
           stationary  device constructed primarily  of  nonearthen
           materials  (e.g.,  wood,  concrete,  steel,  plastic)  that
           provides structural support.

      The basic rationale for these exemptions rests in the  belief
that  most aspects  of wastewater  management  systems   can  be
adequately regulated  under  existing National Pollutant Discharge
Elimination System  (NPDES)  and pretreatment provisions.   Certain
treatment units such as surface impoundments are  nonetheless fully
regulated  under RCRA  because  of their potential effects  on  other
environmental media, especially groundwater.


3.1.1  Regulation of Hazardous  and Solid Waste Landfills

     Landfill units currently are regulated under either  Subtitle
C or  Subtitle D of RCRA,  depending on the  regulatory status  of
wastes managed at  the landfill.   RCRA Subtitle C hazardous  waste

                                12

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regulations  apply,  with  certain  exceptions,  to  landfills  that
presently accept hazardous wastes or have accepted hazardous waste
at  any time  after  November  19,  1980.    Technical  standards for
interim status  hazardous  waste landfills are contained in 40 CFR
Part 265, Subpart N, while RCRA-permitted landfills are regulated
under  provisions contained  in 40 CFR Part 264, Subpart N.  These
standards  apply  equally to  on-site   landfills  maintained  by
hazardous waste generators,  and off-site or commercial landfills
that accept hazardous waste from generators  on a commercial basis.

     The 1984 Hazardous and  Solid  Waste  Amendments  (HSWA) to RCRA
significantly strengthened  controls on hazardous waste landfills
by establishing minimum technology requirements.  These provisions
require the  installation  of double liner and  leachate collection
systems at  new landfills, new landfills at existing facilities,
replacements  of existing  units,  and lateral  expansion of  existing
units.  While these provisions do  not mandate  costly retrofitting
of  existing  portions  of these landfills with  liners and  leachate
collection systems, most  hazardous waste landfills that  retained
interim  status  following  the  November 8,  1987,  deadline  for
groundwater monitoring and financial responsibility certifications
(i.e., the so-called loss  of  interim status certifications) already
have   installed   leachate   collection   systems.      Widespread
installation  of leachate collection  systems at active hazardous
waste  landfills probably  reflects a concern on the part  of these
facilities that any releases to groundwater from these units are
likely to  be detected by groundwater monitoring and may require
expensive cleanup under RCRA corrective  action provisions.

     The extent of leachate collection by landfill  units that lost
interim  status  on November  8, 1986 is  far  less  certain.  While
these  landfills will be required to perform  groundwater monitoring
to comply with RCRA closure requirements,  they are not specifically
required to install leachate  collection systems as  a condition for
unit  closure.   Nonetheless,  where  these units are  found  to be
contaminating  groundwater,  installation of leachate collection
systems  may be necessary to provide long-term control  of unit
releases to groundwater.  HSWA also imposed  severe  restrictions on
the types  of hazardous waste that may be disposed of in  landfill
units.  For  example,  the  Agency has restricted the land  disposal
of  specific hazardous  wastes as necessary to protect human health
and the  environment.   In accordance with a schedule mandated by
HSWA,  EPA currently is reviewing all hazardous wastes  for  possible
land  disposal  restrictions,   and  establishing Best  Demonstrated
Available Technology (BDAT)  treatment standards to control the land
disposal of hazardous  wastes.

     Landfills managing nonhazardous wastes currently are regulated
under  the  RCRA  Subtitle D program.  Subtitle  D  landfills include
municipal/commercial landfills used for the management of municipal
refuse, incinerator ash,  sewage sludge,  and a range of  industrial
wastes, as well as private industrial landfills used  for on-site

                                 13

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management of  industrial wastes.  Current Subtitle  D  criteria for
classification  (40  CFR  Part  257)   state  that  a  landfill  is
considered to  be an open dump  if  it contaminates  an  underground
drinking water source.  However, current regulations do not impose
design  or  operational  standards  such  as  leachate  collection
requirements   on  the  Subtitle  D  landfills.    Nonetheless,  as
evidenced by existing data on Subtitle D facilities, some of these
landfills  already have installed leachate  collection  systems  to
prevent off-site  releases to groundwater.

      Under HSWA,  EPA roust revise Subtitle D criteria that apply to
facilities receiving household  hazardous wastes  or  small quantity
generator  (SQG)  wastes by March 31,  1988.   These  revisions  must
include groundwater monitoring requirements and corrective action,
where appropriate.    Imposition  of  groundwater  monitoring  and
corrective  action requirements  on  these  facilities  will  likely
result  in  increased use of leachate  collection systems to control
re leases  to  groundwater.   EPA also must evaluate  other Subtitle
D land  disposal  facilities  to determine  whether  the  existing
criteria are adequate  to protect human  health and the environment
from groundwater  contamination.

      Landfills that closed  prior  to  the  effective  date of  the
Agency's  hazardous  waste  regulation   (October 30,   1980)   and
nonhazardous waste landfills may be  regulated under RCRA Subtitle
C corrective  action  requirements when located at RCRA treatment,
storage, and  disposal facilities.    Under  1984  corrective  action
amendments, EPA  may require corrective  action  for releases  from
solid  waste   management   units,   including  nonhazardous   waste
landfills  that   could  include  collection   of   leachate  and/or
groundwater pumping discharges.


3.1.2  Regulation of Hazardous  Waste  and PCS  Incinerators

      Hazardous waste  incinerator  units currently  are  regulated
under RCRA Subtitle C.  Technical standards for interim status and
RCRA-permitted incinerators are  outlined  in 40  CFR Part  265,
Subpart 0  and 40  CFR  Part  264, Subpart O,  respectively.   These
standards  apply  equally  to  on-site  incinerators  operated  by
hazardous waste generators, and off-site or commercial  incinerators
that accept hazardous waste from generators on a  commercial basis.

     Current RCRA standards  for permitted  incinerators  require
99.99  percent  destruction  and  removal  efficiency  (ORE)   for
principal organic hazardous constituents  (POHC) and  99.9999  ORE
for  dioxins  and  furans  in the  waste feed  to  the incinerators.
Permitting standards  also  control incinerator  emission  rates  of
hydrogen chloride and particulates.   Although RCRA  interim status
standards do not  directly regulate  emission rates, many  interim
status incinerators already are  equipped with air pollution control
devices to  control emission of  gases  and particulates.   Facilities

                                14

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will generate scrubber liquids and sludges that require treatment
and disposal when  wet systems such as venturi scrubbers are used
for the  control  of incinerator emissions.  Because scrubbers may
be  used  to control  both  gases  (i.e.,  hydrogen  chloride)  and
particulates,  in contrast  with  dry  systems such  as  bag houses,
which control only particulates, generation of scrubber wastewaters
by hazardous waste incinerators will likely increase as incinerator
permitting  progresses.

     Several ongoing  regulatory  and programmatic developments are
likely  to  create  a  shortfall  in  hazardous  waste  incineration
capacity, and may result in the construction and permitting of new
incinerators.   For example,  the land disposal ban program will
curtail  land disposal of certain wastes and will require selection
of  alternative  treatment and  disposal methods for these wastes.
Incineration  already  has been designated  as  BOAT  for a range of
non aqueous solvent wastes, and will likely be defined as BDAT for
numerous organic wastes  considered in the  future.

     Also,  EPA  recently proposed the  regulation  of Subtitle  C
industrial  boilers and furnaces managing hazardous waste,  and is
considering the  imposition  of  emission  controls on  organics,
hydrogen chloride,   and metals  for  these   units.    If  these
restrictions are promulgated,  some industrial facilities may choose
to transfer these wastes from boilers and furnace units to on-site
or off-site incinerators instead of retrofitting existing boilers
or  furnaces to  comply with  new controls.   Wastes generated by
facility clean-ups undertaken  in  response  to the Comprehensive
Environmental    Response,    Compensation   and   Liability   Act
(CERCLA)/RCRA corrective criteria and state  cleanup programs also
will increase the demand for hazardous waste incineration capacity.
The Agency projects a  shortage of incineration capacity as a result
of the land disposal  restrictions  (51 FR 40614).

     Disposal of wastes containing polychlorinated biphenyls  (PCBs)
currently is regulated  under the  Toxic  Substances  Control Act
(TSCA).     Technical  standards   for   PCB  disposal,  including
incineration and burning in boilers and furnaces,  are  contained in
40  CFR Part 761.  In instances  where  PCBs are constituents of a
hazardous waste (e.g., solvents), a permitting official would apply
the more stringent of  the  RCRA or TSCA rules in  regulating the
incinerator operation.


3.1.3  Regulation of Commercial Aqueous Waste Treatment  Facilities

     Commercial  aqueous waste treatment facilities  use numerous
physical, chemical, and biological processes (e.g.,  neutralization,
chemical precipitation, and biological treatment) for the treatment
of aqueous  hazardous  waste from off-site  generators.   Presently,
the treatment processes themselves are not directly regulated under
RCRA   Subtitle   C  unless  the  hazardous  wastewater   treatment

                                15

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operations are conducted in surface impoundments rather than tanks.
Surface impoundments are regulated  as  hazardous waste treatment,
storage, and disposal (TSD)  units under RCRA Subtitle C, and must
comply   with   stringent    technical   standards    (e.g.,   liner
requirements, groundwater monitoring) designed primarily to prevent
the release  of  waste constituents  to  groundwater.  RCRA technical
standards do not, however, regulate effluents discharged from these
units to surface waters or POTWs.


     RCRA  technical  standards  also may apply  to  ancillary waste
management operations such  as  storage or other TSD units (i.e.,
incinerators  or landfills)  where  the aqueous hazardous  waste
treatment  operation is  part  of an  integrated hazardous  waste
facility.   Where a commercial aqueous hazardous  waste treatment
facility has at least one  regulated TSD unit  on-site,  the facility
becomes  RCRA-regulated  TSDF and  accordingly is subject  to RCRA
corrective action requirements.  Under RCRA corrective action, the
facility  may be required to address releases  from regulated TSD
units   and  solid   waste  management   units  (SWMUs),  including
wastewater treatment units,  located at the site.
 3.2  DISCUSSION OF WQA REQUIREMENTS


 3.2.1  Regulation of Direct Discharges to Surface Water

     Under the Clean Water Act (CWA),  direct discharges to surface
 waters   are   controlled  through  the   imposition   of  effluent
 limitations contained in NPDES permits issued by authority of CWA
 Section  402.  Effluent limits developed by a permit writer may be
 based on the following guidelines promulgated by authority of CWA
 Sections 301 or 306:

          Best practicable control technology currently available
          (BPT) - intended to provide an initial set of discharge
          controls on the discharge of conventional pollutants from
          existing sources.

          Best available technology economically achievable  (BAT)
             intended  to  provide  additional  controls  on the
          discharge of toxic and nonconventional pollutants.

          Best conventional pollutant control technology (BCT)  -
          intended to provide additional controls on the discharge
          of conventional  pollutants (i.e.,  BOD,  TSS,  pH,   fecal
          coliform, and oil/grease).

          New source  performance standards  (NSPS)  -  intended to
          provide discharge controls  for new  sources.

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The current framework for control of toxic pollutants is contained
 ? .a settlement  a9reement  negotiated  in  1976  between  EPA  and
plaintiff  environmental  groups.   This  agreement  required EPA to
develop a  program and adhere to  a  schedule for promulgating BAT
effluent   guidelines,   pretreatment  standards   (for   indirect
dischargers),   and   new   source  performance  standards  for  65
pollutants and pollutant  classes potentially discharged by  21 major
industries  [see Natural  Resources Defense Council v. Train. 8 ERC
2120  (D.D.C.)].   The basic  elements of  the  NRDC consent decree
subsequently were codified in the 1977 CWA amendments.

     While  addressing most  major manufacturing  industries,  the
consent  decree  currently does  not  encompass waste  management
facilities  such  as  landfills,  incinerators,  and  aqueous waste
treatment facilities.  As a result of longstanding RCRA exemptions
for hazardous wastes disposed of and treated in wastewater systems
(both direct and  indirect) as well as expected additional demands
by hazardous waste handlers  on the use of wastewater systems due
to RCRA  regulatory  actions  and decreased  disposal  capacity for
CERCLA wastes, the Office of Water  (OW) is reviewing the need for
developing  additional wastewater discharge limitations.   In part,
this  OW response is  based  on  Section  3018 (b)  of RCRA,  which
requires that the Agency  promulgate additional wastewater treatment
requirements for  indirect dischargers, as the Administrator deems
necessary  as  a result of  the  findings of  the 3018(b)  Report to
Congress.

     The  U.S.  EPA's  "Report  to  Congress  on   Hazardous  Waste
Discharges to Publicly-Owned  Treatment Works" determined that POTWs
were  handling significant  quantities of  hazardous constituents
discharged  by  categorical  industries,   improvements   to  the
pretreatment programs would result in enhancing POTW capability to
control  such  discharges, and  that  further  study was necessary,
particularly  with  respect  to the  rates  and effect  of  those
pollutants.  The  report  did not address the quantity, type, fate,
and effects of hazardous waste constituents discharged by direct
dischargers; however, existing data  on the practices of hazardous
waste handlers suggest that direct discharge wastewater systems are
used for hazardous constituent treatment.

     EPA has  not yet promulgated effluent  guidelines  to assist
permit writers in formulating NPDES  permits  for  hazardous waste
treatment facilities.  In the absence of  these guidelines, permit
writers must rely wholly on  their own best professional judgment
(BPJ) in setting  limits  for discharges by these facilities.  This
process requires  a  permit writer  to make complex, site-specific
determinations,  often   evaluating   factors  such   as  wastewater
characteristics,  pollutant  concentrations,   available  pollution
control technologies, and water quality constraints.

     New source performance  standards (NSPS)  may have particular
importance  for  the   HWT industrial  sector,  due  to  increasing

                                17

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restrictions on  certain waste  management practices  (e.g.,  land
disposal).  Some industrial facilities may  choose to send wastes
off-site  to  commercial  facilities  in lieu of  pursuing on-site
management options.   These trends  will  increase the  demand for
commercial treatment  and  disposal  capacity,  and result  in the
siting and construction of new commercial facilities.  Applicable
discharge controls are likely to represent a key consideration in
the design and construction of these facilities.

     Wastewaters generated by on-site hazardous  waste treatment
units  such  as  landfills  and  incinerators   are  not  addressed
specifically  by  effluent  guidelines  for  specific  industrial
categories  covered by  the  NRDC  consent  decree.   For  example,
effluent  guidelines do  not establish process-specific limits for
scrubber  wastewaters from on-site hazardous waste incinerators or
leachate  from on-site industrial landfills.  Existing  permit limits
may  not  offer  adequate control  in  instances where  hazardous
residuals contain different pollutants (e.g., dioxins, furans) or
pollutants in greater  concentrations than  other plant wastewaters.
Again,  where  effluent  guidelines  do not  specifically  cover  a
certain wastewater generated by  an individual facility, the permit
writer must exercise BPJ in developing appropriate limits  for these
waste  streams.  Nonetheless,  where pollutants  contained  in these
wastewaters are  identified as similar to pollutants contained in
other  regulated waste  streams,  the  NPDES  permit  limits should
provide some control of constituents contained in residuals from
hazardous waste  treatment units.


3.2.2     Regulation  of  Indirect  Discharges   to  Publicly-Owned
          Treatment Works

     Under the  CWA, discharges  to Publicly-Owned Treatment Works
(POTWs)  are controlled through  the imposition  of  pretreatment
standards promulgated  by  authority of CWA Section 307.   These
standards apply to wastewater discharged by  an  industrial  facility
to  a  POTW collection  system.    Certain  types  of  pretreatment
standards, referred to as national  categorical standards, apply
uniformly to all facilities determined to be within the scope of
the regulated industrial category.  Categorical standards  include:

          Pretreatment  standards  for  existing sources  (PSES)  -
          intended to pro vide controls on pollutant  discharges by
          existing sources.

          Pretreatment standards for new  sources (PSNS) -  intended
          to  provide   controls  on  pollutant  discharges  by new
          sources.

As mandated by the NRDC  consent decree and 1977 CWA amendments, EPA
is required to  promulgate categorical pretreatment  standards for
the 21 major industries  enumerated  in the consent decree.

                                18

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     General prohibitions prevent the discharge of pollutants that
interfere with POTW treatment processes or pass through the POTW,
causing  water quality  violations.    Other  specific prohibitions
 ?J   K dlschar
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                    4.  HWT INDUSTRY PROFILE
     The hazardous waste treatment  (HWT)  industry includes those
facilities  that  generate  and  discharge  wastewaters to  surface
waters or Publicly-Owned Treatment  Works (POTWs) as  a  result of
RCRA-regulated activities  involving the  storage, treatment,  or
disposal of toxic wastes.  This  industry  can produce wastewaters
by the following methods:


          Treatment  and  discharge  of  aqueous   liquid  hazardous
          wastes.

          Discharge  of  air pollution  scrubber  wastewaters  from
          incinerator operations.

          Leachates from landfills.  For the  purpose of this study,
          the  term  leachate  refers  to  all  landfill  aqueous
          discharges.


     As discussed in Chapter  3, the discharge of these wastewaters
to surface  waters  and  POTWs  is not regulated by  RCRA,  nor is it
covered by other categorical  standards.

     Although the HWT industry has been studied extensively  for its
management  of  hazardous  wastes,  there are  limited  data  on the
generation and disposal of  wastewaters  from these  facilities.  EPA
has not yet undertaken a detailed and  comprehensive  study of the
wastewater generated by the HWT industry; therefore,  a definitive
profile of this industry  is not available.  However,  current data
bases  and  the literature  have been reviewed  and   evaluated;  a
telephone verification of  information  supplied  by TSDFs  to EPA
under authority of RCRA was undertaken for a small segment of the
industry; and  EPA  regional  and State environmental files  were
reviewed to  help  to profile this industry.  This effort  has resulted
in a preliminary profile,  which  is  presented in  this Section and
includes:

          The types of facilities and their operations

          The number of facilities

          The geographic  distribution of the industry

          Their methods of discharge.
                                     20

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4.1  DEFINITION OF THE HWT INDUSTRY

     For the purpose of this study, the HWT industry  is defined as
follows:                          '

          Commercial   HWT   facilities,    including   commercial
          incinerators, landfills, and  aqueous treaters

          Incinerators  at   on-site  generators  that  discharge
          scrubber  wastewater

          Landfills at on-si,te generators that collect and dispose
          of leachate

          Municipal landfills that collect and dispose of leachate

          Subtitle D landfills that collect and dispose of leachate

          On-site generators not regulated by categorical standards
          that  discharge wastewater associated  with their  TSD
          operations.

As a result of this definition, the HWT industry consists primarily
of  noncategorical  facilities  (e.g.,   facilities  not  currently
regulated by categorical  discharge standards); however,  a number
of facilities regulated by categorical discharge standards are also
commercial  HWT  facilities,  and therefore are included  in  this
definition.  An example of such a facility is the DuPont Deepwater,
New Jersey  facility,  which  is an organic  chemicals manufacturing
plant  (OCPSF category) that accepts aqueous hazardous waste from
the entire United States  for comingling and treatment.

     Noncategorical on-site generators are an ill-defined group of
facilities. Included  in this grouping are Paragraph 8 industries
and Federal facilities such  as Army depots and Department of Energy
government  owned  and  contractor   operated   (GOCO)  facilities.
Although  included in  the HWT  industry,  the  data  available  for
noncategorical on-site generators  are limited.


4.2  DESCRIPTION OF THE HWT INDUSTRY

     The HWT industry  can  be divided into three major subcategories
for the purpose of this study:

          Leachate treatment  facilities - provide collection and
          treatment of aqueous discharge from on-site, commercial,
          municipal, private, hazardous waste, industrial, and/or
          Subtitle  D  landfills.   These   discharges  can  include
          leachate collected at the bottom of the landfill and any
          groundwater removed from the  water table.


                                     21

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           Incinerator scrubber wastewater treatment  facilities -
           limited to those  facilities  treating only incinerator
           scrubber wastewater or on-site generators of incinerator
           scrubber wastewater that combine the incinerator scrubber
           wastes with other  wastewaters for  treatment.

           Aqueous hazardous  waste treatment facilities  -  provide
           physical,   chemical,   and/or   biological  treatment  of
           hazardous   and  nonhazardous  wastewaters,   including
           leachate from on-site and off-site landfills and process
           wastewaters from  on-site  and  off-site  manufacturing
           operations.  Whereas  leachate treatment  facilities  only
           handle on-site generated wastewaters,  commercial aqueous
           treaters handle  a variety  of  wastewaters,   including
           leachate.
 4.2.1  Landfills and Leachate  Collection  and Treatment

      Landfills commonly are  described by  the types  of wastes  that
 they accept or by their design. Some of the terms used to describe
 types of landfills  are  municipal,  sanitary, chemical, industrial,
 secure,  RCRA, hazardous waste,  Subtitle C, and Subtitle D. Although
 municipal landfills  do not knowingly accept hazardous wastes,  they
 can contain  these wastes due to disposal practices  that occurred
 prior to  RCRA.   The HWT industry  includes all  landfills  that
 discharge leachate.

      As   a  result  of  past  design  practices,   most Subtitle D
 landfills do not have leachate  collection systems or liners.  These
 landfills were designed with  the intent of using the natural  soils
 and groundwater  flow system to attenuate  the leachate generated by
 the wastes.   The difficulty  in finding appropriate  sites and  the
 growing  concern  that the contaminant loadings generated exceeded
 the attenuative  capacity of  even the most  suitable sites led to
 the concept  of containment designs.   Containment landfills have
 clay or  synthetic liners along with leachate collection systems.
 Depending on the  design of the  landfill, higher groundwater flows
 into the  site may result in higher leachate generation rates.

      Most Subtitle C landfills  that retained interim status after
 November  7,  1985,  have liners  and  leachate collection;  however,
 only  new landfills  and expansions  and  replacements of interim
 status landfills are required to have a double liner with leachate
 collection under the 1984 Hazardous and Solid  Waste Amendments
 (HSWA) to RCRA.  Loss of Interim Status (LOIS) landfills continue
 to  generate leachate,  although they no longer  accept wastes  and
 are undergoing closure.

     As a result of past practices and regulations  (both RCRA  and
state), leachate  collection  is limited to  a  small  percentage of
the  landfills  existing  in the United States.   Current design

                                22

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practices  and regulations have  resulted in the  installation of
liners and leachate collection systems  in  the  new cells as they
are opened at Subtitle C landfills.   The result is an increasing
volume of  leachate  that  requires treatment  and disposal.

     Subtitle C and  some  Subtitle D  landfills  presently screen
incoming wastes.  Screening can range from spot checks of municipal
refuse trucks to extensive  sampling and quality  assurance  (QA)
procedures,  which can result  in the barring  of  trucks carrying
banned wastes.   Screening by Subtitle D facilities is important,
since  RCRA regulations  require  that Subtitle  D  facilities only
accept nonhazardous wastes.   A  list  of  excluded  wastes often is
posted at  Subtitle  D facilities  and is provided to regular users
of the facility.

     Subtitle C  facilities  are  required  to  obtain  a  detailed
physical and chemical analysis  of a representative sample  of wastes
accepted for burial.  In addition,  RCRA prohibits the landfilling
of  bulk  or  noncontainerized  liquids,  nonhazardous   liquids  in
Subtitle   C  landfills  and  liquids  adsorbed  in   materials  that
biodegrade or release liquids  when compressed, and some solvents.
These prohibitions are fairly recent  (since  1984, and in some cases
November   1986),   and  consequently,   existing  hazardous  waste
(Subtitle  C)  landfills  contain the  prohibited   wastes,  having
accepted these wastes in the past.


4.2.2  Incinerators and  Scrubber Wastewater

     The most common type of  incinerator in hazardous waste service
is liquid  injection,  representing  64 percent of the incinerators
in  1981.    Liquid  injection  incinerators  can burn only  liquid
wastes.  The  next most common  types of incinerators are the fixed
hearth and the rotary kiln.  Both of these  will dispose of solids
and/or liquid wastes, including containerized  wastes  and drums.
RCRA   regulations   require    that   permitted  hazardous   waste
incinerators  achieve  99.99 percent destruction for each principal
organic hazardous constituent  designated in the facility's permit
for each waste feed.   Incinerators permitted to burn dioxins and
furans  are  required  to  achieve   99.9999  percent  destruction.
Incinerators burning polychlorinated biphenyls (PCBs) are regulated
under the  Toxic Substances Control Act (TSCA), not RCRA.  Interim
status  facilities  are  not  required to   meet  any  performance
standards.

     RCRA  requires that permitted hazardous  waste incinerators
control hydrogen chloride gas (HCl) and particulates in  their stack
emissions.  Most facilities, including those with  interim status,
are equipped with at least one  air  pollution control device. These
devices  include  venturi  scrubbers,   ionizing  wet  scrubbers,
baghouses,  and  electrostatic  precipitators.    The venturi  and
ionizing   wet  scrubbers remove  both  gases  and  particulates,

                                23

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generating  scrubber  wastewaters for treatment  and disposal; the
baghouses, which are dry,  remove only particulates.  Electrostatic
precipitators can be either wet or dry.

     Commercial hazardous waste incineration facilities screen the
wastes  that they accept to ensure compliance  with their  interim
status  RCRA  or  final  RCRA  permit  requirements.    Screening
procedures  include analyses of representative waste samples,  spot
checks of incoming shipments,  or bans on  specific waste types. For
example, only TSCA incinerators will accept  PCB-containing  wastes.
Some  facilities  also refuse to accept certain  wastes because of
limitations in their air emissions permit or local  limits in their
wastewater  (pretreatment) permit.

     Presently,  there are  less than  six  incinerators  that are
permitted by TSCA to burn PCB-containing wastes.   It  is believed
that only a few years remain in the PCS incineration market due to
declining generation of PCB liquids and  the preferred method of
chemical destruction of these wastes rather  than incineration. PCB
incinerators then  will be used  to destroy  other  RCRA wastes or
PCB-contaminated solids.
4.2.3  Acrueous Hazardous Waste Treaters

Aqueous hazardous waste treaters provide treatment of wastewaters
containing high  concentrations  of  toxic or hazardous pollutants.
Aqueous  treaters include  both  on-site  generators  that  are not
regulated  by categorical  discharge  standards but  treat process
wastewater,  and  commercial hazardous  waste treaters.   Commercial
treaters provide a service to other facilities that cannot provide
treatment on-site.  Facilities that transport wastes to commercial
aqueous hazardous waste treaters include:

          Landfills that choose not  to provide treatment on-site
          or do  not have  an acceptable receiving stream or  sewer
          line available

          On-site operators who find  it more  cost-effective to
          contract haul their waste to a commercial facility.

Commercial  hazardous  waste  treaters  differ  from  centralized
treatment  systems  in that centralized treatment  facilities are
designed to treat one type of waste, and usually only accept  waste
from  a  fixed  number  of  clients.   For  example,   a number of
electroplaters in  one  community  may  use  one  central  treatment
facility for treatment  of their common  wastewaters.   Commercial
aqueous hazardous waste treaters handle a range of hazardous wastes
and will accept any wastes that pass their screening procedures.

     Treatment provided at the  commercial  waste  treaters may
include  pretreatment  of   specific waste  types  (e.g.,  cyanide

                                24

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destruction), physical/chemical  treatment,  biological treatment,
and tertiary treatment.  The attraction of aqueous hazardous waste
treatment  is that  the  treated  effluent is excluded  from  RCRA
regulations, which  only regulate the storage and handling of the
wastes before and during treatment  [40  CFR 261.4(a)(2)].  No RCRA
performance standards  exist  for  these treatment systems, although
the final  effluent  must meet either National Pollution Discharge
Elimination  System  (NPDES)  permit  limitations  or pretreatment
standards. Wastes treated by these  facilities include:

        Pesticides                       •  PCBS
     •  Plating baths                    .  Paints and  inks
        Cyanides                         .  Metal bearing wastes
        Flammable wastes                •  Halogenated organics
         Acidic wastes                  •  Nonhalogenated organics
        Caustics                         .  Reactives
        Oily wastes                     •  Halogenated solvents
         Commercial chemical products    •  Nonhalogenated solvents
        Leachate from  hazardous  waste landfills

     Commercial aqueous  hazardous waste treaters also are required
to screen  the wastes that they receive.   RCRA regulations require
a  chemical/physical  analysis  of  a representative sample.    In
addition,  some commercial facilities limit the types of waste that
they  will  accept   for  treatment  due   to restrictions  in  their
operating  permit,  limitations   in  the  capabilities  of  their
treatment  systems,  and/or  effluent limitations  in their NPDES or
pretreatment permits.


4.2.4  Integrated Facilities

     The   HWT  industry includes   a  number of  large,  complex
facilities  that offer a  variety  of  hazardous waste management
services  at a single  facility-  These  facilities  can  include an
incinerator, an aqueous treatment system,  and a landfill.  Although
presently  there  are only a few of these  integrated facilities, a
survey  of the RCRA Part B  applications indicated that  a large
number of  the commercial facilities are  planning to  expand into
integrated facilities  by offering additional services  at existing
sites.

     Currently,  many  commercial facilities  serve  as  brokers for
their customers. That is, a  commercial facility will accept wastes
from a customer  even  though it  is  unable to treat it at its own
facility-  However, the commercial facility will arrange to have
the waste  treated at another commercial  facility.   In  this way, a
generator  does not  have to search for and ship each unique waste
to a different commercial facility.
                                25

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4.3  NUMBER OF HWT FACILITIES

     The following sections  present estimates of the number of HWT
facilities by  subcategory.   The estimates reflect  data gathered
from numerous  sources,  which have  been used  to develop  a best
estimate of the number of facilities in each subcategory.


4.3.1  Landfills

     Table 4-1  presents  an estimate  of the number  of hazardous
waste and  Subtitle D landfills  in  the United States  using data
collected from numerous sources.  The  Office of Solid Wastes (OSW)
February 1987 report lists 49 commercial hazardous waste landfills,
which corresponds  closely  to a  1985  publication (Ref.   8)  that
includes 43 facilities.   The OSW  count includes one facility whose
permit was denied. While both of these sources report only active
landfills, the Hazardous Waste Data Management System (HWDMS) data
base includes landfills undergoing closure.  The February 1987 OSW
report listed 18 landfills undergoing  closure, including 11 that
have not  submitted a  closure  plan.   The remaining discrepancy
between HWDMS and the OSW counts is probably due to the fact that
HWDMS includes  five or six  protective filers  and a few landfills
that subsequently have been  reclassified as waste piles or surface
impoundments.

     Environmental Information's (E.I.'s)  Directory  contains 34
landfills, which  is  the smallest number of  commercial hazardous
waste landfills.  This directory  is a  sourcebook for generators in
search of  a commercial  firm to serve their needs.   Commercial
facilities are  listed in the  directory based  on response  to a
questionnaire distributed by E.I.

     For the  purpose  of  this analysis, the  number  of commercial
hazardous waste landfills  was  estimated to  be 67.   This number
represents the sum of the active (49)  and closure (18) facilities
taken  from  OSW's  report.    Facilities  undergoing  closure were
included  in  the  estimate  because  leachate  generation  does  not
necessarily cease with the closure of a site.

     The HWDMS  data base estimates  155 hazardous waste landfills
at  categorical generators  and  an  additional  146  landfills at
generators not regulated by categorical discharge standards.  The
146 includes 15 municipal waste landfills.  EPA data indicated that
approximately 20 percent of  the active TSD facilities in the HWDMS
data base  lost  interim status  and  were  required  to  close by
November 8,  1985.  Since the breakdown of these facilities with
and without  leachate collection  systems is  not available, it was
assumed that the  loss of interim status (LOIS)  facilities do not
have leachate collection; therefore, the number of hazardous waste
landfills  at  on-site generators  with leachate  collection  as
required by RCRA was estimated at 240 (e.g.,  80 percent of 301).

                               26

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           TABLE 4-1.   ESTIMATE OF THE NUMBER OF HAZARDOUS WASTE
                         AND SUBTITLE  D LANDFILLS
                                       Estimated Number of HW Landfills

                                Commercial Noncommercial* Categorical
                                Facilities   Facilities   Industries  Total
OSW Report on
  RCRA Permit Activities8
49
"Hazardous Waste Consultant" Listb  43

E.I.'s Directory of Industrial and
  Hazardous Waste Management Firmsc  34
HWDMS Data Base
 75
146
155
376
*    Other than commercial facilities
a     Reference 1
b     Reference 2
0     Reference 3
Source of Data
Estimated Number of Subtitle D Landfills
Active Subtitle D Landfillsd
     Municipal Waste
     Industrial Waste
     Demolition Debris
     Other
                       16,416
                        9,284
                        3,511
                        2,591
                        1,030
     Reference 4
                                     27

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All of these facilities are  expected  to have leachate collection
systems,  resulting in wastewater discharge.

     OSW's Subtitle  D  Study  Phase I  report  estimated that there
were 16,416  active  Subtitle  D  landfills  in  1984.   Of these, 57
percent are municipal,  21 percent were industrial, and 16 percent
were demolition debris landfills.  The report also concluded that
53  percent  of  all  municipal   landfills  receive  small  quantity
generator  (SQG) hazardous wastes.

     In this EPA-ITD study, only landfills with leachate collection
or   groundwater  recovery  are  considered  part  of  the industry.
Therefore, an estimate of the number of facilities that discharge
leachate is necessary.   Table 4-2 presents  such an estimate.  This
table shows that of the 16,416 Subtitle D landfills, only 604 had
leachate collection, while 4,927 rely on the underlying soils to
provide leachate treatment.  Approximately half of the 604 leachate
collection systems provide treatment for the discharge.


Method of  Discharge

     Table 4-3 presents a summary of the available data regarding
the treatment  and disposal of  leachate.   The table includes data
from both hazardous  waste and Subtitle D facilities.   These results
do not represent an unbiased, independent survey of landfills and
should not be interpreted as such.  The data were collected as part
of an effort to locate potential sampling candidates,  and therefore
may be biased toward leachate collection and treatment.  However,
based on this information,  a  preliminary breakdown of the leachate
subcategory, by discharge type,  is  19 percent direct, 40 percent
indirect, and 41 percent other dischargers. Most  facilities  in the
other category claimed to be  zero  dischargers,  however,  it is
anticipated  that  most  of  these facilities will  have occasional
discharges due to maintenance,   shutdowns, etc..   Applying these
percentages  to the estimated  number  of landfills  with leachate
systems  (911,  see Table 4-8),  results in 173 direct dischargers,
355 indirect dischargers and 383 other.

     Discharge to a  POTW appeared to  be the  most common leachate
treatment/disposal  method,  which  is  a   reflection  of  several
factors.    First, municipalities tend  to send leachate from their
landfills  to their  POTW rather  than  incur the  expense of either
constructing  and  operating  a  leachate treatment  plant  at  the
landfill or  opting  for  some other  disposal method.   Leachates
either are trucked  or  sewered  to the POTW.   In  most cases,  the
leachate volume represents a small  fraction of the  flow  to the
POTW.   Privately  operated  Subtitle D  landfills  also tend to use
POTWs,  since  they provide convenient  and relatively  inexpensive
leachate  treatment/disposal.     In  addition,   some  commercial
landfills  (both hazardous  waste and  Subtitle D)  provide on-site
leachate treatment,  but discharge the treated leachate to a POTW.

                                28

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     TABLE 4-2.  LEACHATE MANAGEMENT AT SUBTITLE D LANDFILLS
(1)
Landfill Type
Municipal 3,677
Industrial 657
Demolition Debris 541
Other 52
Total 4,927
Leachate Leachate
Collection Treatment Leachate
Systems Systems Recirculation
481 245 205
112 69 27
5 10
6 20
604 317 232
Source:  Reference 5

NOTE:

(1)  Landfills  that  do  not  have leachate  collection  systems or
     liners.
                                   29

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       TABLE 4-3.  LEACHATE TREATMENT/DISPOSAL PRACTICES -
                    SUMMARY OF AVAILABLE DATA
                                                   Number of
                                                   Facilities
Leachate Disposal Practice                       Supplying  Data*


Discharge to NPDES Outfall                             19
Discharge to POTW                                      39
Solidify and Rebury                                     6
Off-site Disposal at a Commercial Treater              14
Deep Well Injection                                     7
Surface Impoundment                                     7
Incineration                                            2
Land Application                                        1
No Leachate Generated                                   3
     Total                                             98
*  Includes both hazardous waste and Subtitle D landfills
Sources:

     1)   SAIC verification study
     2)   SAIC 1986 and 1987 sampling efforts
     3)   Data from state agencies
     4)   Reference 6
     5)   Reference 7
                               30

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This   arrangement   may   reflect   limited  on-site   treatment
technologies, liability considerations, permitting and regulatory
issues,  or   the   location  of  the  landfills  near  a  sewered
metropolitan  area.

     The second most common disposal practice appeared to be direct
discharge through  an NPDES outfall,  followed closely by off-site
disposal  at  a  commercial  treater.   Both  hazardous  waste  and
Subtitle D  landfills located  in  unsewered  areas most  frequently
discharge  to surface waters,  although they  might truck  their
effluent to a POTW  for treatment.

     Contract hauling of  leachate  to commercial  aqueous  waste
treaters is  also  a common practice at hazardous waste landfills.
In  addition,   several  hazardous  waste  landfills  have  become
commercial aqueous hazardous waste treaters. These landfills have
taken  advantage of their extensive leachate treatment  systems by
accepting off-site-generated aqueous hazardous wastes for treatment
in their facility along with their leachate.

     Solidification and  reburial  is  a practice used  by several
facilities.   This  option  is  popular  when  leachate volumes  are
small.  Deep well injection was common  among landfills in Alabama,
Texas, Oklahoma, and Louisiana.  Landfills  in the arid West either
do  not  generate  leachate  or  use surface impoundment  (i.e.,
evaporation)  for  the disposal of the small volumes of  leachate
generated.

     In summary, the size of the leachate subcategory was estimated
at 911 facilities.   This  included all  of the commercial hazardous
waste  landfills  (67)  plus  the Subtitle  D and hazardous  waste
landfills   with  leachate  collection  systems   (604   and  240,
respectively).


4.3.2  Incinerators and Scrubbers

     Table 4-4 presents estimates of the number of hazardous waste
incinerators.   The data  in  the table  have been  compiled  from
several  sources.    Both  the HWDMS data base and EPA's directory
estimated the number of commercial hazardous waste incinerators to
be 42.  E.I.'s  directory  includes 40 commercial  incinerators.

     Three  sources  provided  estimates  of  the  total  number of
incinerators  that  burn  hazardous waste.    The  HWDMS data  base
estimated this  number at  376,  which  included  164  at categorical
industries  and  170  at  noncategorical  facilities  (not including
commercial industries).  Mitre Corporation's survey  of incinerator
manufacturers  reported  a  total  of  342  incinerators  sold  for
hazardous waste use since  1969, or 34  less than  the HWDMS.  Units
sold prior to 1969 may account  for the difference between the HWDMS
and Mitre estimates.

                                31

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TABLE 4-4.  ESTIMATE OF THE NUMBER OF HAZARDOUS WASTE INCINERATORS
                                      Estimated Number
                    Commercial Noncategorical* Categorical
Source of Data      Facilities   Facilities    Industries   Total
OSW Report on RCRA
  Permit Activities"      —          —              —         230

EPA's Directory of
  Commercial Facilities"  42

Mitre Corporation Survey
  of Manufacturers0       —          —              —         342

HWDMS Data base           42         170             164         376

E.I.'s Directory of
  Industrial and Hazardous
  Waste Management Firms"  40

                   Average                                     316
*    Does not include commercial facilities
     Reference 1
     Reference 8
c     Reference 9
     Reference 3
                                32

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     OSW's  February  1987  report estimated  the total  number of
hazardous waste  incinerators at 230,  which is considerably below
the  other  estimates.    Part of  the  discrepancy  may be  due* to
reclassification  of  many  of these  incinerators  as  boilers  and
industrial  furnaces.   As boilers  and  industrial  furnaces,  the
facilities  are no longer TSDFs  and are not subject to RCRA permit
and  interim status regulations,  even though  they  may be burning
hazardous wastes.

     For the purpose of this study,  the  number of incinerators was
estimated to be  316,  which is the average of the three estimates
shown in Table 4-4.
Method of Discharge

     Mitre Corporation's survey indicated that all incinerators in
hazardous waste  service have been equipped with at least one air
pollution  control  device.    Table  4-5  presents  a  summary  of
available  data  showing the  treatment/disposal of the scrubber
wastewaters.   This table presents data only for known  facilities
and cannot be  considered as  a  cross-section of  the industry-  The
data in  Table  4-5 indicate that the majority of the incinerators
have  wet  scrubbers.   This  is  expected, since  RCRA-permitted
incinerators are required  to control stack emissions of hydrogen
chloride gas,  necessitating  the use  of a wet scrubber.  Table 4-5
also shows that  the  majority (50  percent)  of scrubber wastewaters
are discharged to surface waters.  This occurs  because a  relatively
large  number  of  hazardous  waste   incinerators  are  located  at
facilities  that  discharge  wastewater  generated  from  process
sources.  These  facilities comingle  the scrubber wastewaters with
their  process wastewaters  in  their on-site  treatment systems,
resulting in discharge of  the scrubber wastewaters through NPDES
outfalls.  The large commercial incinerators treat their scrubber
wastewaters in a dedicated treatment system prior to discharge to
a POTW or NPDES outfall, depending on the location of the facility.
Only incinerators with small  volumes  of  scrubber wastewater are
expected to use  off-site treatment/disposal methods.  Of the four
facilities reporting no scrubber wastewater, two have baghouses and
the remaining  two report that they have no air pollution control
system in-place.   Based on the information presented in Table 4-
5, the breakdown of the scrubber subcategory by discharge method
is estimated to be 137 direct dischargers,  27  indirect dischargers
and 109  other  dischargers.

     RCRA  regulations  required  wet scrubbers  for only  the 230
facilities  that   are  in the  process of obtaining  RCRA permits.
Other incinerators, probably reclassified as boilers or  industrial
furnaces, may or may not have wet  scrubbers. No data are available
for these  incinerators.   Therefore, the  number of incinerators
generating scrubber  wastewaters ranged from a minimum of 230 to  a
maximum  of  316   (i.e., the  estimate  of  the  total   number  of

                                33

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   TABLE 4-5.   MANAGEMENT OF INCINERATOR SCRUBBER WASTEWATER -
                    SUMMARY OF AVAILABLE DATA
                                             Number  of  Facilities
Scrubber Wastewater Disposal Method             Supplying Data


Discharge to NPDES Outfall*                             10

Discharge to POTWs                                       2

Off-site Disposal at a Commercial Treater                2

Landfill                                                 2

Surface Impoundment/Evaporation                          1

No Scrubber Wastewater                                   4
*    Includes  incinerators  at  on-site  generators that  combine
     scrubber wastewater with process wastewaters for treatment and
     discharge

Sources:

    1)   SAIC verification study
    2)   SAIC 1986 and 1987 sampling efforts
                               34

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incinerators burning hazardous wastes).  Averaging the two numbers
(230 and  316)  produces an estimate  of  273 facilities generating
scrubber wastewaters.
4.3.3  Aqueous Hazardous Waste Treaters

     Estimates of  the  number of aqueous hazardous waste treaters
are presented  in Table 4-6.  The  HWDMS  data base estimates that
there are 154 commercial aqueous treaters.   In the foreword to its
1987 directory,  E.I.  indicated that over  150 firms were deleted
from its 1986 edition in compiling the 1987 version  as a result of
closure  or nonresponse to  E.I.'s  inquiries.  At the  same time,
other  facilities were added.  This  suggests that the  HWDMS data
base  and  EPA  Directory,  dated  1985  and  1986,  respectively,
estimates may be outdated. The 1986 National Survey that used HWDMS
for its mailing  list may  have resulted in  the elimination of some
commercial  firms  due  to  closure,  but may not have  added newer
firms/ resulting  in  an underestimate of  the commercial aqueous
hazardous waste  treatment facilities.

     For  the purpose of this study,  an  average  of  all four data
bases  has been used to estimate the  size  of the industry-  This
resulted  in  a  total count of 125 for commercial aqueous hazardous
waste  treatment  facilities.

     Only HWDMS  and the 1986 National Survey provided estimates of
the  noncategorical aqueous hazardous waste treaters.    The two
estimates,   913  and  280  facilities,  respectively,  are  vastly
different.   An average of the two values  provided  an estimate of
approximately   600 noncategorical  facilities  treating   aqueous
hazardous wastes.
Method of Discharge

      Table 4-7  summarizes the available data regarding the fate of
aqueous hazardous wastes.   The data were collected as part of an
effort to locate potential sampling candidates and therefore may
be biased toward treatment and discharge.  Based on these data, the
breakdown of the aqueous treater subcategory by  discharge method
was estimated to be 86 direct dischargers, 515 indirect dischargers
and  124 other  dischargers.

      Discharge to  a  POTW  was the  most common aqueous  hazardous
waste  disposal  method.   The  prevalence of  this method was  a
function of location;  most POTWs are located in metropolitan  areas
near  the  industries  that  they serve.   Other facilities  serving
large  regions  of  the  country   are  located   near  convenient
transportation routes that may  or may  not  be  in  metropolitan
sewered  areas,  resulting  in  some  discharging  through  NPDES
outfalls.

                                35

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              TABLE  4-6.   ESTIMATES OF THE NUMBER OF
                 AQUEOUS  HAZARDOUS WASTE THEATERS
                                    Estimated Number
                     Commercial Noncategorical* Categorical
                     Facilities   Facilities     Industries  Total
EPA's Directory of
  Commercial Facilities*  134           —

E.I.'s Directory of
  Industrial and Hazardous
  Waste Management Firms6 120

HWDMS Data base           154          913

1986 National Survey of HW
  Wastewater Treatment
  Facilities0             91          280             —        1023

         Average          125          597


*    Other than commercial facilities
*     Reference 8
b     Reference 3
c     Reference 10
                                36

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   TABLE  4-7.   DISPOSAL OF WASTEWATERS  BY  FACILITIES MANAGING
      AQUEOUS  HAZARDOUS WASTES - SUMMARY OF AVAILABLE  DATA
                                            Number of Facilities
Wastewater Disposal Method                     Supplying Data


Discharge to NPDES Outfall                            5

Discharge to POTW                                    30

Off-site Disposal at  a  Commercial Facility            3

Deep Well Injection                                   2

Incineration                                          1

Off-site Disposal at  a  Landfill                       1


Sources:

     1)  SAIC verification  study
     2)  SAIC 1986 and  1987 sampling  efforts
     3)  USEPA,  ORD,  HWERL  reports
     4)  Published literature
     5)  Data from state agencies
                                37

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4.4  GEOGRAPHIC DISTRIBUTION OF THE HWT INDUSTRY

     EPA Regions  V and VI  have  the largest  number of hazardous
waste landfills and incinerators; Texas has the largest number of
these facilities.  Among the Subtitle D landfills, West Virginia,
Pennsylvania, and Texas had the largest number, with approximately
1,200 in each state.  Texas also had the largest number of Subtitle
D municipal  landfills,  followed closely by .Wisconsin. These two
states each  accounted  for  10  percent  of  the total.   Pennsylvania
had by far the largest number of Subtitle D industrial landfills,
accounting for 30 percent of the  total  as reported by  an EPA study
(Ref. 4).

     EPA Region V also  had the  largest number of hazardous waste
incinerators; Texas has the largest number of these facilities.

     In addition,  EPA Region  V has the largest number of aqueous
waste treatment  facilities.   Region III  is a  distant second.  A
large  number  of  categorical  industries   were  treating  on-
site-generated  aqueous  hazardous  waste.     Assuming  that  the
industries have not constructed dedicated  hazardous waste treatment
systems, the aqueous hazardous wastes  were comingled and treated
with the process  wastewater at these facilities.   The categorical
industries (OCPSF, inorganic chemicals, metal  finishing, petroleum
refining, and electrical  and  electronic  components) reported the
largest numbers of facilities treating aqueous hazardous wastes.


4.5  HWT INDUSTRY SIZE ESTIMATE SUMMARY

     Estimates of the number of facilities potentially included in
the HWT industry  are summarized in Table 4-8.   The table presents
the  estimates  by subcategory  and  type  of   facility for   each
subcategory.  The industry size was estimated at  facilities based
on currently available  data.  The future size of this industry  will
be affected by current and proposed RCRA regulations.


4.6  FINANCIAL CHARACTERISTICS OF COMMERCIAL FACILITIES

     EPA has collected  financial  data  on some  firms operating
commercial  hazardous waste  treatment and disposal   facilities.
These data allow  the calculation of financial ratios  to provide a
picture of some  financial characteristics of  the industry.   The
data available  for the  ratio calculation are:   net income,  cash
flow, net  worth  and total  assets.   Two  financial  ratios  are
presented in Table 4-9:  net income to total assets and cash  flow
to total assets.   As shown on  the upper part of the table,  the
average of  the net  income to  total  assets  is   8.9  percent for
publicly-owned  firms and 5.1 percent  for privately  held firms.
Similarly,  the average of the cash flow  to total assets ratio is
13.4 percent and 11.4  percent  for  public  and  private  firms,

                                38

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TABLE 4-8.  HAZARDOUS WASTE TREATMENT INDUSTRY PROFILE
                 Number of Facilities
Subcategory Name
Landfills
Conner ica I
Non- commercial
Subtitle D Landfill
Total

Incinerators
Comercial
Non-commercial
Total

Aqueous waste treaters
Conner ica I
Non-commerical
Total

Facility Prod.
Total Waste Water

67
301
16,416
16,784


42
274
316


125
600
725


67
240
604
911




273


125
600
725

Direct Discharge Handled Other
Discharger to POTW by Hauling Discharge




173 355 128 255
19% 39% 14% 28%



137 27 27 82
50% 10% 10% 30%



87 515 51 72
12% 71% 7% 10%
                           39

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       TABLE 4-9.  STATISTICS OF SELECTED FINANCIAL RATIOS
                       FOR THE HWT  INDUSTRY
                    Net Income/Total Assets  Cashflow/Total Assets
Finanical Ratio              (%)                       (%)
                      Public      Private      Public       Private
No. of Firms in Sample
Average
Minimum
Maximum
Standard Deviation
10
8.9
2.0
17.1
4.6
230
5.1
-20.6
51.2
5.6
10
13.4
3.1
17.1
6.4
177
11.4
-9.7
71.6
10.4
Statistics of Complete Sample (Public - Private)
                    Net Income/Total Assets  Cashflow/Total Assets
Finanical Ratio              (%)                       (%)


No. of Firms in Sample       240                       187

Average                      5.3                     11.5
Minimum                    -20.6                     -9-7
Maximum                     51.2                     71.6

Standard Deviation           5.7                       9.5
                                40

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respectively.   These  estimates inherit  considerable dispersion
shown by wide  range of values and large standard deviation, thus
the  average ratios  of the  public  firms cannot  be  shown  to  be
statistically  different from those of private  firms.   The lower
part of the table presents  the  calculated  ratios for the entire
sample with the public  and private firms.

     A smaller group of 18  firms has been  selected by EPA to be
surveyed annually as commercial hazardous  waste  treatment firms
(Ref. 11) .  This  group is the best representation of firms whose
major business is the treatment and disposal of hazardous waste.
Financial data are available for 14 of  the 18  firms.  Financial
ratios for  these  firms have been calculated and are presented in
Table 4-10.  The  average  ratios  appear to be higher than those of
Table  4-9,  but  again  the  differences are   not  statistically
significant.
4.7  COMMERCIAL HAZARDOUS WASTE MANAGEMENT PRICE


     Table  4-11 presents the range of service prices for several
waste  management technologies. The general ranking of fees of the
treatment   and  disposal  processes   are,   from   high  to  low:
incineration;  chemical  treatment  (aqueous  treatment); hazardous
waste landfill; and municipal landfill.  However,  within each type
of treatment or disposal, prices vary  considerably in relation to
waste  composition,  form of  the  waste,  and  so  on.    In  1985,
incineration costs ranges from $0.10-4.17 per gallon for typical
liquids, and in the range of $2.10-8.30 per gallon  for highly toxic
liquids.  The  low end of the range was for liquids with a high BTU
content,  which  helps  in the incineration  process.   Chemical
treatment  cost  ranged  from  $0.12  to  $6.00  per  gallon,  with
relatively  low fees  for acid/alkaline wastes and  high  fees for
highly toxic wastes.  Hazardous waste landfill charges ranged from
$69-140/ton  ($0.29 to 0.58 per gallon)  for bulk waste, and $50-137
per  drum  ($0.91  to  2.50 per  gallon) for  containerized waste.
Municipal landfill fees  range from $2.05 to 37.37/ton. All prices
have increased between 1983 and 1985, with incinerator and chemical
treatment having  the largest percentage increases,  and deep well
injection having  the  smallest  increase.  With  the short supply of
incinerator capacity, these price increases are likely to continue.
4.8  SUMMARY


          The HWT  industry  was  divided  into  three  subcategories:

                     Landfills   with   leachate   collection   and
                     treatment   facilities

                                          41

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  TABLE  4-10.   STATISTICS OF  SELECTED FINANCIAL RATIOS FOR THE
                SELECTED  FIRMS IN  THE  HWT INDUSTRY
                    Net Income/Total Assets  Cash flow/Total Assets
Financial Ratio              (%)                       (%)


No. of Finns in Sample        14                       13

Average                      7.6                     18.0
Minimum                      2.0                     11.4
Maximum                     17.1                     23.3

Standard Deviation           4.3                      4.1
Source:  Ref. 11
                               42

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            TABLE  4-11.
COMPARISON  OF HAZARDOUS  WASTE MANAGEMENT PRICES  (PER  GALLON)
     QUOTED BY ALL FIRMS  IN 1983,  AND  1985  a/
                                                     Price ($ per gallon unless otherwise indicated)
Waste Management
Technology
Landfill
Land Treatment/Solar
Evaporation
Incineration
Chemical Treatment
Resource Recovery
Deep Well Injection
Transportation
Type or Form of Waste
o 55-gallon drum
o Bulk
All
o Clean liquids,
high Btu value
o Liquids, low Btu
o Sludges and solids
o Highly toxic liquids
o PCB liquids
o PCB solids
o Acids/alkalines
o Cyanides
o Highly toxic wastes
o Heavy metals
o Organics
o Oil
o Oily wastewaters
o Toxic rinse waters
0
1983
25-60/drum
25-90/ton
0.02-0.09
(0.05)c/-0.25
0.35-1.00
1.50-3.10
0.06-0.55
0.50-3.10
0.14-1.30
0.05-0.15
0.50-1.10
.08-0.17/ton-mi.
1984
25-100/drum
40-150/ton
0.02-0.09
(0.05)c/-0.35
0.30-1.25
1.30-4.20
0.06-0.85
0.85-6.00
(0.06)c/-3.00
0.07-0.28
0.50-1.20
0.14-0.20/ton-mi.
1985
50-137/drum
69-140/ton
0.33-0.83
0.10-1.93
1.33-4.17
2.75-4.25
2.10-8.30
2.50-3.50
4.50-12.50
0.12-2.00
0.50-0.90
2.80-6.00
0.20-1.00
(0.25)-3.00b/
0.00-0.42
0.08-0.50
0.50-1.20
0.18-0.22/ton-mi.
2. 70-4. 50/loaded
Percentage change in
1986 relative to 1985
*10-25%
*10-20%
*15%
•15-50X
*15-50%
*15-50%
*15-20%
*10-20%
No change
*10%
*10-20%
*10-25%
*30%
*30%
*10-25%
*10-25%
                                                                           mile (20 tons per load)
a/ Interviews conducted in April 1983, Hay-July 1984,  August 1985, and August-September 1986.
b/ Range for mixed halogenated solvents is $2.20 - $4.20 per gallon.
c/ Some cement kilns, light aggregate manufacturers, and steel mills pay for wastes used as fuel.
d/ High end of range can be as much as $6.00 per gallon if reactives are included.
Sources:  Booz, Allen and Hamilton Inc. for 1983 figures.
         ICF Incorporated for 1984 and 1985 figures.

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               Incinerators with scrubber wastewaters

               Aqueous hazardous waste treaters.

     The  number  of  facilities  in  each  subcategory  was
     estimated as follows:


Subcategory                             Number of Facilities

Landfills with leachate systems                   911
Incinerators with scrubber wastewaters            273
Aqueous hazardous waste treaters                  725


     The most  common  method of wastewater disposal  for the
     landfill   and   aqueous   hazardous   waste   treaters
     subcategories is to POTWs.  Incinerators with scrubbers
     are more commonly direct dischargers.  The breakdown by
     discharge method  of  each subcategory was  estimated as
     follows:

                              Number of Facilities
                       Direct       Indirect       Other

Leachate                 173           355           383
Wet Scrubber             137            27           109
Aqueous Treaters          87           515           123
     Other   dischargers    include   deep   well   injection,
     incineration,  off-site disposal, land  application,  and
     solidification and burial.

     EPA Regions V and VI have the largest number of hazardous
     waste landfills and  incinerators.  The largest number of
     aqueous waste  treatment facilities  is in EPA Region V.
                               44

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                  5.   RAW WASTE CHARACTERIZATION


     This section characterizes  and analyzes the raw wastes found
in    each  of  the  hazardous   waste  treatment   (HWT)  industry
subcategories:     leachate,   scrubber  wastewater,  and  aqueous
hazardous waste.   The  data  presented in  this  section have been
compiled from three sources:   (1)  sampling activities  at 12 sites
during  1986  and   1987,   (2)   data  compiled  from   other  U.S.
Environmental   Protection Agency  (EPA)   studies  and  sampling
programs, and  (3)  the  scientific  literature.   This section also
presents  a  discussion  of  analytical methodology and  factors
affecting the recovery  of pollutants and their  quantification.


5.1  POLLUTANT ANALYSIS,  RECOVERY, AND QUANTIFICATION

     In  order   to  interpret  fully  analytical  data,  quality
assurance/quality  control   (QA/QC)  information  must first  be
evaluated.   This is especially  true  for  the analysis of organic
pollutants. Of particular concern  in organics analysis is percent
recovery.  For example, if 100 nq/1 of a compound is reported, but
the percent  recovery  is 50 percent,  the real concentration could
range from 100 to  200 M9/1-  Conversely, if the recovery is 1,000
percent,  the real concentration  could  be  10 M9/1*    Expected
recoveries for organic compounds using Contract  Laboratory Program
(CLP)  protocols are  60  to  150 percent  and for  pesticides  the
recovery is 60 to 200 percent.  The percent recovery for a compound
becomes increasingly important when concentrations are low  (i.e.,
near their detection limits).

     The  detection limits  for the various  organics  in  the  HWT
industry sampling  effort  ranged from 10 to 5,000 nq/l, depending
on the compound  and the  sample.  Several potential reasons include:

          A  sample  extract containing a large  amount  of organics
          can overload the gas chromatograph/mass spectrophotometer
          (GC/MS) .  Consequently, the full-strength extract cannot
          be run, making dilutions necessary and resulting in high
          detection limits.

          Some  detection  limits are  high,  even in "clean water."
          For example,  the detection limit  for some  organics in
          reagent water is 10 M9/1/ while in others it is 250 M9/1-

          High  concentrations   of  a  few compounds  can  swamp
          everything else.   In this  case,  it may be necessary to
          use large dilutions to quantify  the compounds present in
          high concentrations, thereby diluting those found  in low
          concentrations.  When the full strength extract is rerun
          to detect and quantify the low concentration compounds,
          the high concentration compounds mask their  presence.

                                     45

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          A  study  conducted  for the  Office  of  Research  and
          Development/Hazardous   Waste   Environmental   Research
          Laboratory  (ORD/HWERL)  on  landfill leachate  has shown
          that less than 5 percent of the  TOC in leachate can be
          identified  using  EPA's  GC/MS methods.    Part  of  the
          problem is that leachate contains complex organic acids
          (humic and fulvic materials),  which  are not identifiable
          using GC/MS methods.

          Some polar compounds (such  as  organic acids) are readily
          soluble in water,  and are  hard to separate and analyze
          with a  GC.   Furthermore,  some  polar compounds  do not
          extract well  during  the  extraction  procedure.   Some
          analytical chemists believe that less than 5 percent of
          the phenols, benzoic acid,  and other organic acids found
          in leachates are actually extracted.


     Analytical problems  such as  these were experienced  by the
laboratories  used during the 1986-87  sampling programs,  which
resulted  in pollutants  not  being  found  in  samples,   when  high
concentrations  of these  pollutants had  been  found in similar
wastewaters in other samples.  Therefore,  the data collected from
other  sources are  critical  to  the analysis presented  in  this
section. Future Industrial Technology Division (ITD) sampling and
analysis efforts will be designed to correct these problems.

     Currently, EPA  programs use two sets of analytical methods for
toxic organics analysis.  The  Office  of  Water, including  ITD,  uses
the 1600 and 600 Series methods (40 CFR Part 136) , while the Office
of Solid Waste (OSW)  uses the  8000 Series  analytical methods and
the 3000 and  5000 Series sample preparation methods (40 CFR Part
261).   For the most  part, the methods are identical;  however, two
critical differences exist between the methods:


          The  600 and  1600  Series  methods  (e.g.,  the  "water
          methods")  include specific QC acceptance  criteria  that
          must be met in  order  for the  analyses  to  be  valid.
          Limited acceptance  criteria were  specified for  the 8000,
          3000, and  5000  Series methods  (e.g., the "RCRA methods")
          in the second edition of SW-846, the test methods manual.
          The  analyst  ran QA/QC  checks and  reported  the QA/QC
          results along with the  analyses,  but  the  QA/QC results
          did not have  to  fall within  critical ranges.   In the
          third edition of the Resource Conservation and Recovery
          Act (RCRA) methods, published in November 1986  (Ref. 12),
          acceptance criteria and  critical ranges  are specified;
          however, data obtained prior to November 1986 using the
          RCRA methods  do  not  have  as  stringent  QA/QC  as  data
          obtained with the water methods.

                                     46

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          The water methods require that the analyst follow a set
          procedure,  step by step, regardless  of the wastewater
          sample.    The  RCRA  methods  allow   the  analyst  more
          flexibility to  adjust for  sample matrix.   That is, the
          analyst   can   cleanup   a   sample  to   reduce  matrix
          interferences if  necessary  and to the extent necessary
          prior  to  analysis.   In  the  second edition  of the RCRA
          methods,  as  long as the QA/QC  checks were  run through
          the same cleanup  and  analytical procedures,  the results
          were acceptable.  The third  edition of the RCRA methods
          formalizes  the  cleanup  procedures  as the  3000 Series
          methods,  but  allows the analyst  the  choice of cleanup
          procedure on a  sample-by-sample basis.

     As a result of the  flexibility  in  the RCRA methods and the
cleanup procedures available to reduce sample matrix interferences,
data obtained  using these  methods show  higher  concentrations of
pollutants and the presence of more pollutants.   These observations
will be apparent in the following sections, which present data from
sources other than this EPA-ITD study.,  including two studies using
RCRA methods.

     Variability  inherent  in  the   methods   used   to  analyze
conventional and nonconventional pollutants also must be evaluated
in  order to  interpret analytical data.   For  example,  EPA-ITD
analytical  results for BOD5.  are  only accurate to +  30 percent
within a 95 percent degree of confidence.   Consequently, dissolved
BOD5_,  a fraction  of  total BOD5,  can be  reported within method
accuracy  limits, to be  60 percent greater than total  BOD5.   A
similar  circumstance exists  for  ammonia, a  fraction  of  total
Kjeldahl nitrogen.  The levels  of  precision and accuracy reported
by EPA-ITD are for analyses conducted on natural  water  samples, not
the complex matrices found in samples collected  during this study.
Furthermore, precision  and accuracy  data  are  not  available for
parameters such  as  COD and  solids.
5.2  LEACHATE

     The following sections summarize the pollutants found in raw
leachate. Data were obtained from numerous sources as indicated on
the data tables. Individual listings of the data  are presented in
Appendix A.


5.2.1  Sources of Raw Waste Data

     The most recent source for analytical data characterizing the
raw leachate is the 1986-1987  EPA-ITD study sampling effort.  Six
landfills  with  leachate  collection  were sampled during  this
program.    The  landfills  sampled  contained municipal  refuse,

                                47

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industrial wastes, and  hazardous  wastes.   The  ITD sampling data
are supplemented by analytical data obtained from:


          ORD/HWERL  sampling  efforts  at   13   hazardous  waste
          landfills in 1985

          Wisconsin  Department  of  Natural  Resources  sampling
          efforts at 20 municipal landfills containing municipal,
          industrial, and hazardous wastes during 1983

          EPA Office of Emergency  and  Remedial  Response Contract
          Laboratory Program  (CLP)  Statistical data  base,  "Most
          Commonly Occurring  Analytes  in  56 Leachate  Samples,"
          1980-1983 data

          National   Enforcement   Investigations   Center   (NEIC)
          sampling  program conducted   for  the  Hazardous  Waste
          Groundwater Task Force during 1985

          Subtitle D  leachate data for miscellaneous Subtitle D
          landfills,  compiled by OSW.


The  data  vary in  the  pollutants reported  (i.e.,  conventionals,
nonconventionals, metals,  toxics,  organics); the number of samples
collected at each facility; and the data guality-  QA/QC data are
available only for the ITD and ORD/ HWERL sampling efforts.


5.2.2  Pollutants in the Raw Leachate
5.2.2.1  Conventional and Nonconventional Pollutants

     Tables   5-1  through   5-7   summarize  the   conventional,
nonconventional, and inorganic toxic pollutant data collected from
the previously  discussed  sources.   The data  show that leachates
contain  high  concentrations  of  BOD5_,  COD,  and  TOC.    These
pollutants are  indicators  that there are high  concentrations of
both inorganic and organic compounds in leachates.

     The  fact  that  leachates are high-strength wastes  also is
reflected in the presence  of other pollutants,  specifically TSS,
TDS, chloride, TKN,  and ammonia.   These  pollutants were found in
a wide range of concentrations.  Studies have shown that leachate
strength is affected by  a number  of  factors,  including landfill
design,  precipitation and  runoff, types  of wastes  landfilled,
landfill age, groundwater  infiltration,  geographic location, and
geologic conditions.   Under these circumstances,  it may be expected
that hazardous  waste landfills  that  are the most  secure  (i.e.,
synthetically lined to exclude precipitation and groundwater) would

                                48

-------
       TABLE 5-1.
CONTAMINANT CONCENTRATION RANGES IN LEACHATE
      REPORTED IN THE LITERATURE
Parameter
PH
Alkalinity
Acidity
Total Solids
TDS
George
(1972)
(Ref. 27)
3.7-8.5
0-20850


0-42276
Total Suspended Solids 6-2685
Specific Conductance
BOD
COD
TOC
Bicarbonate
Hardness
Chlorides
Fluorides
Sulfates
Sulfide
Total-K-Nitrogen
NH3 -Nitrogen
Organic Nitrogen
NO3-Nitrogen
Total Phosphorus
Ortho-Phosphorus
Aluminum
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Total Chromium
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Potassium
Sodium
Titanium
Vanadium
Zinc
9-54610
0-89520


0-22800
34-2800

1-1826

0-1416
0-1106

0-1300
1-154







5-4080

0-9.9

0.2-5500
0-5.0
16.5-15600
0.06-1400



2.8-3770
0-7700


0-1000
Chi an
DeWalle
(1977)
(Ref. 28)
3.7-8.5
0-20850

0-59200
584-44900
10-700
2810-16800
81-33360
40-89520
256-28000

0-22800
4.7-2467

1-1558


0-1106

0.2-10.29
0-130
6.5-85





0.03-17
60-7200

0-9.9

0-2820
<0. 10-2.0
17-15600
0.09-125



28-3770
0-7700


0-370
Metry
Cross
(1977)
(Ref. 29)
3.7-8.5
310-9500


100-51000
13-26500
100-1200
2200-720000
800-750000

3260-5730
35-8700
47-2350

20-1370


0.2-845
2.4-550
4.5-18

0.3-136






240-2570



0.12-1700

64-547
13



28-3800
85-3800


0.03-135
Cameron
(1978)
(Ref. 30)
3.7-8.5
0-20900
0-9590

0-42300


9-55000
0-9000


0-22800
34-2800
0-2.13
0-1826
0-0.13

0-1106



0-154
0-122
0-11.6
0-5.4
0-0.3
0.3-73
0-0.19
5-4000
0-33.4
0-10
0-0. 11
0.2-5500
0-5.0
16.5-15600
0.06-1400
0-0 . 064
0-0 . 52
0 . 01-0 . 8
2.8-3770
0-7700
0-5.0
0-1.4
0-1000
Note:  All concentrations  in mg/1 except pH (standard units) and
       specific conductance  (umhos/cm)
                                   49

-------
TABLE 5-2.  CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS AND METALS
      SUMMARY IN RAW LEACHATE EPA-ITD STUDY  SAMPLING RESULTS
Ranae of Concentrations (1)
Pollutant
BOD5, mg/1
COD, mg/1
TOC, mg/1
TSS, mg/1
TDS, mg/1
Chloride, mg/1
O&G, mg/1
Ammonia-N, mg/1
TKN, mg/1
NO2 and NO3-N, mg/1
Fluoride, mg/1
Sulfide, mg/1
pH, SU
Phenols, mg/1
Cyanide, mg/1
TVO, mg/1
Calcium, mg/1
Magnesium, mg/1
Sodium, mg/1
Aluminum
Iron
Manganese
Boron
Barium
Molybdenum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Minimum
24
36
63
5
1,554
72
<1.0
14
14
—
<0.1
<0.1
6.7
<0.05
<0.01
—
43
39
87
20
6,800
450
170
57
—
<10
<5
<1
<5
<10
6.6
<2
<50
<0.2
33
<5
—
<10
<13
15
4.4
<10
4.1
Maximum
5040
17,300
5,500
4187
13,800
1839
552
350
479
—
8.7
0.75
8.66
1.95
0.07
—
1,600
335
1,520
3,300
718,000
59,300
13,000
975
—
<10
63
2
<5
214
217
46
<50
<0.2
200
<5
—
<10
<13
100
92
64
26,600
Mean (2)
1001
3225
912
1467
5,245
855
69
154
165
— —
1.2
0.21
— -"
0.76
0.04
— —
346
137
623
1,300
134,700
11,800
4,980
366
18
<10
32
2
<5
74
70
36
<50
<0.2
174
<5
7.0
<10
<13
59
41
42
4,380
Percent of Samples
Where Pollutant
Was Detected (3)
100
100
100
100
100
100
67
100
100
™" ^
33
17
~~
75
67
— —
100
100
100
92
100
100
100
100
8
0
75
17
0
92
67
50
0
0
83
0
8
0
0
75
67
33
100
                                50

-------
       TABLE  5-2.   CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS
                  AND METALS SUMMARY IN RAW LEACHATE
              EPA-ITD STUDY SAMPLING RESULTS  (Continued)
NOTES:

(1)  All concentrations expressed in y.g/1,  unless  otherwise noted.

(2)  Mean concentrations were calculated based on  all the analyses
     in  the   EPA-ITD  Sampling   program   where   the  pollutant
     concentration was higher than the detection  limit.

(3)  Data presented  are  based on a total of 12 samples.  Percent
     of samples  where pollutant was detected reflects the number
     of  samples  where  the  pollutant  was  detected   above  the
     detection limit.  For example, molybdenum was detepted ;Ln one
     sample, or  8%  (1/12 x  100%)  of  the  samples.

-------
         TABLE 5-3.  OVERALL SUMMARY FROM THE ANALYSIS OF
           MUNICIPAL SOLID WASTE LEACHATES IN WISCONSIN
Parameter Overall Range*
TDS
Specific Conductance
Total Suspended Solids
BOD
COD
TOC
PH
Total Alkalinity (CaCO3)
Hardness (CaCO3)
Chloride
Calcium
Sodium
Total Kjeldahl Nitrogen
Iron
Potassium
Magnesium
Ammonia-Nitrogen
Sulfate
Aluminum
Zinc
Manganese
Total Phosphorus
Boron
Barium
Nickel
Nitrate-Nitrogen
Lead
Chromium
Antimony
Copper
Thallium
Cyanide
Arsenic
Molybdenum
Tin
Nitrite-Nitrogen
Selenium
Cadmium
Silver
Beryllium
Mercury
584-50430
480-72500
2-140900
ND-195000
6.6-97900
ND-30500
5-8.9
ND-15050
52-225000
2-11375
200-2500
12-6010
2-3320
ND-1500
ND-2800
120-780
ND-1200
ND-1850
ND-85
ND-731
ND-31.1
ND-234
0.87-13
ND-12.5
ND-7 . 5
ND-250
ND-14.2
ND-5.6
ND-3.19
ND-4.06
ND-0.78
ND-6
ND-70.2
0.01-1.43
ND-0.16
ND-1.46
ND-1.85
ND-0.4
ND-1.96
ND-0.36
ND-0.01
Typical Range
(range of Number of
site medians)* Analyses
2180-25873
2840-15485
28-2835
101-29200
1120-50450
427-5890
5.4-7.2
960-6845
1050-9380
180-2651
200-2100
12-1630
47-1470
2.1-1400
ND-1375
120-780
26-557
8.4-500
ND-85
ND-54
0.03-25.9
0.3-117
1.19-12.3
ND-5
ND-1.65
ND-1.4
ND-1.11
ND-1.0
ND-0.56
ND-0.32
ND-0.31
ND-0.25
ND-0.225
0.034-0.193
0.16
ND-0.11
ND-0.09
ND-0.07
ND-0.024
ND-0.008
ND-0.001
172
1167
2700
2905
467
52
1900
328
404
303
9
192
156
416
19
9
263
154
9
158
67
454
15
73
133
88
142
138
76
138
70
86
112
7
3
20
121
158
106
76
111
Note:  ND = not detected

*A11 concentrations in mg/1 except pH (standard units)  and specific
conductance (umhos/cm)
                                52

-------
    TABLE 5-4.  MOST COMMONLY OCCURRING
    CONVENTIONALS,  NONCONVENTIONALS,  AND
METALS IN LEACHATE SAMPLES — CLP  DATABASE,
               1980-1983 DATA
Ranae of Concentrations*
Pollutant
Ammonia, mg/1
Fluoride, mg/1
Cyanide, mg/1
Calcium, mg/1
Magnesium, mg/1
Sodium, mg/1
Aluminum
Iron
Manganese
Boron
Barium
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Tin
Vanadium
Zinc
Minimum
17.0
—
0.033
92.2
29.7
40.8
300
160
270
0
227
—
0
0
3.3
21
24
36
10
0
60
0
0
0
40
Maximum
51.0
—
2.50
109
68.7
84.9
2,700,000
4,300,000
650,000
4,500
160,000
—
1,900
59
2,100
22,400
5,400
100,000
75,000
70
12,000
40
72
5,900
320,000
Mean
34.0
0.4
1.266
62.6
43.1
69.6
364,501
458,514
100,149
1,486
19,798
—
392
25
426
3,649
1,052
16,761
8,536
26
2,362
20
36
1,215
19,177
Number of
Analyses
2
1
2
3
3
3
12
18
13
10
9
1
6
4
5
9
6
6
9
4
6
2
2
5
18
All concentration expressed in
                               unless otherwise noted.
                      53

-------
     TABLE 5-5.  CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS
              AND METALS IN MISCELLANEOUS SUBTITLE D
                        LANDFILL LEACHATES
                    Range of Concentrations(l)    Number of Samples
                                                  Where Pollutant
Pollutant          Minimum    Maximum      Mean    Was  Detected
COD, mg/1
TOC, mg/1
BOD5 , mg/ 1
TSS, mg/1
TDS, mg/1 1
Ammonia as N,
mg/1
TKN, mg/1
Chloride, mg/1
Fluoride, mg/1
Total Cyanide, mg/1
Sulfate, mg/1
Sodium, mg/1
Calcium, mg/1
Magnesium, mg/1
Arsenic
Barium
Cadmium
Chromium, Total
Beryllium
Copper
Iron 1
Lead
Manganese
Mercury
Nickel
Selenium
Zinc
Antimony
Silver
Thallium
Cobalt
440
<5
7
29
,400
11.3

66
120
0.12
0.004
8
183
96
76
<1
200
<0.1
1
5
3
,700 1,
<1
260
<0.1
40
<1
<10
470
<10
80
* —
15,820
6,880
9,044
310
10,100
1,200

938
5,475
0.79
0.02
346
929
516
927
80
500
40
180
10
150
300,000
1,050
43,000
6.0
1,070
20
67,000
1,100
50
80
— ~
3,689
2,115
2,275
218
5,696
290

477
785
0.42
0.012
98
480
248
225
30
327
16
57
7.5
69
214,000
188
11,190
2.0
346
10
8,440
785
30
80
40
16
8
8
3
9
17

3
18
4
2
12
6
5
7
7
6
9
10
2
10
17
12
9
7
9
7
15
2
5
2
1
NOTE:

(1)   All concentrations expressed in ng/1, unless noted otherwise,
                                54

-------
              TABLE  5-6.   POLLUTANTS IN HAZARDOUS WASTE
                 LANDFILL LEACHATES  - ORD/HWERL STUDY
                               Range of Detected
                               Constituentm (2)
Parameter
Minimum
Maximum
     Percent of Sites
	  Where Pollutant
 Mean    Was Detected
COD (mg/1)
TOC (mg/1)
Total Cyanide (mg/1)
pH (SU)
Eh (volts)
Conductivity (micromhos/cm)
Temperature (°C)
Silver
Arsenic
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Antimony
Selenium
Thallium
Zinc
1,950
195
0.01
7.1
-0.343
4,250
19.9
0.3
458
0.2
0.7
0.2
2.3
0.045
17.3
0.3
13
221
9.4
5.12
23,300
11,750
55
9.3
-0.093
20,000
32
32.8
129,600
7.4
102
1,734
17,030
39.3
67,110
1006
5240
3488
156
24,510
10,217
3,097
9.9
—
-0.226
14,694
26.7
6.6
13,097
0.81
18.7
281
1,885
5.0
6,417
116
522
1,168
36.9
2,513
100
100
69
—
100
100
100
100
77
46
100
100
100
92
100
100
85
100
85
100
NOTES:

 (1)  All concentrations expressed in ug/1,  unless otherwise noted.

 (2)  Data presented are the results of sampling efforts at 13 sites,
     Data collected from each site are summarized in Appendix A-l,
     Table  7.
                                      55

-------
     TABLE 5-7.
POLLUTANTS IN HAZARDOUS WASTE  (SUBTITLE C)
LANDFILL LEACHATES - NEIC STUDY
                  Range of Concentrations(I)(2)
Pollutant
 Minimum
Maximum
Mean
Percent of Sites
 Where Pollutant
   Was Detected
TOC, mg/1 11
TVO, mg/1
Ammonia as N,
mg/1
Cyanides, mg/1
Phenols, mg/1
Fluoride, mg/1
Chloride, mg/1
Bromide, mg/1
Sulfate, mg/1
Nitrate, mg/1
Sodium, mg/1
Calcium, mg/1
Magnesium, mg/1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron 1
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc
NOTES :
,410
470
8.

0.
0.
1.
460
25
32
20
53
68
24
149
220
63
270
29
23
59
23
40
,100
64
345
1.
243
90
33
488
220
61
305

30,400
810
7 5,000

013 77.1
14 370
5 24
37,000
970
11,000
460
25,000
4,950
906
929,000
1,700
1,600,000
6,230
56
841,000
102,000
12,300
2,800
4,080,000
11,600
131,000
1 14
38,900
3,820
35
2,080
25,400
2,160
38,800

(1) All concentrations expressed in /xg/1
(2) Data presented
repr
esents the res
20,905
640
1,328

8.9
93.4
8.8
13,460
417
2,833
124
6,420
832
248
166,580
712
125,620
1,441
42
117,800
7,859
1,305
603
495,030
1,374
16,514
4.0
7,767
762
34
1,284
6,598
484
7,367

, unless noted
ults of the l
100
100
100

90
100
100
100
100
100
71
100
100
100
73
58
86
59
10
50
64
59
86
100
50
100
36
95
41
13
14
50
77
95

otherwise.
NEIC Studv
     sampling  at  6 sites.  Appendix A-5 contains the sampling data
     used  to prepare  this table.
                                  56

-------
have the highest concentrations of conventional, nonconventional,
and  toxic  pollutants.    However,  when  the municipal  landfill
leachate  data  (Tables 5-2  through 5-5) and  the hazardous waste
landfill  leachate  data  (Tables 5-6 and  5-7) were compared, this
hypothesis was found to be  invalid.  A  likely explanation is that
the  high COD,  BOD5,  TOC,  TSS,  TDS,  chloride,   ammonia,  and TKN
concentrations found in municipal landfill leachate are the result
of anaerobic decomposition of paper and paperboard  products.  High
organic  concentrations  (COD,   BOD,  TOC) also might be attributed
to leachate contact  with   sugars and starches found in municipal
landfills.
5.2.2.2  Toxic Pollutants
Metals

     Metals data for leachate samples are summarized in Tables 5-1
through 5-7.  These data  show that:


          Leachates contain  almost all of the metals, ranging in
          concentration from below detection limits to hundreds of
          milligrams per  liter

     •    Subtitle  D  landfills contain  metals at  concentrations
          equivalent to hazardous  waste  landfills.


Generally, leachates have been found to contain high concentrations
of boron, aluminum, iron, manganese,  and zinc.

     Toxic metals, such as arsenic, barium, copper,  chromium, lead,
mercury,  nickel,  and  zinc,   are  found  at  a   wide  range  of
concentrations and in many cases at very high concentrations.  For
example,  arsenic ranged  from not  detected  (ND)  to 70.2  mg/1 in
Wisconsin leachate samples  (Table  5-3),  and from 63  jug/1 to 1,260
mg/1 in NEIC  leachate  samples   (Table 5-7).  Antimony, beryllium,
cadmium, molybdenum, selenium, silver, and tin generally were found
at low concentrations.
Organic Compounds

     Data  for  organic pollutants from six studies are summarized
in Table 5-8.  In some studies a given compound may not be reported
because the leachate was not tested for that compound, not because
the compound was not present in the leachate.  The information from
the EPA-ITD Study,  CLP data base, Wisconsin  Study, and from  other
miscellaneous Subtitle D landfills in Table 5-8 present the organic
compounds  found  in  primarily Subtitle  D  landfill  leachates,  using

                                57

-------
TABLE 5-8   ORGANIC COMPOUNDS FOUND IN RAW LEACHATE
(POLL
«

44
25
11
87
23
7
10
13
27
85
30
26
6
14
32
20
16
552
R138
88
15
46
45
R366
29
50

86
HC250
55
4
38
V074
904

81
POLLUTANT NAME

Methylene Chloride
Dich I orobenzene
1,1,1-Trichloroethane
Trichloroethylene
Chloroform
Chlorobenzcne
1,2-Dichloroethane
1,1-Ddichloroethane
1 , 4 - D f ch I orobenzene
Tetrachloroethylene
Trans,-1,2-Dichloroethytene
1 , 3 - T r i ch I orobenzene
Carbon Tetrachloride
1,1,2-Trlchloroethane
1 ,2-D
-------
TABLE 5-8  ORGANIC COMPOUNDS FOUND IN RAW LEACHATE (CONTINUED)
POLL.
#

77


56

78
1
39
84
72
74
75
76
557

569



930


65
944
943




947
34




POLLUTANT NAME
	
1-Ethyl-2-Methyl Benzene
Acenaphthylene
Tetramethyl Benzene , Isomer
Propyl Benzene
Nitrobenzene
1,3- Dimethyl benzene
Anthracene
Acenaphthene
Fluoranthene
Pyrene
BenzoC a ) Anth racene
Benzo(b) F I uoranthene
Benzo( k) F I uoranthene
Chrysene
Aniline
H,N-Dimethyt Acetamide
4-ChXoroaniline
1-Methyl-2-Pyrrolidinone
Isoquinoline
Azepin-2-One, Hydro-, 2H-
Pyridine
2-Chloro-Pyridine
4-Methyl Benzenesulfonamide
Phenol
4-(P-Cresol )Methylphenol
Benzoic Acid
Butanoic Acid
2-Methyl-Propanoic ^cid
Pentanoic Acid
Alkanoic Acid
Hexanoic Acid
2,4-Dimethylphenol
Phenytacetic Acid
4-(Methylthio)-Phenol
Octanoic Acid
2-Methyl-ButBnoic Acid
EPA I TO STUDY
No. Mi n Max Mean
	
0000


0000

0000
0000
0000
.0000
0000
0000
0000
0000
0000








0000
0000





J» 0 0 0
H) 0 0 0




CLP Database
No. Min Max Mean

1 15 15 15


1 10 10 10
1 4600 4600 4600
4 16 25 20
3 45 45 45
3 10 60 28
3 8 53 25
2 13 16 14
2 11 11 11
2 11 11 11
2 16 16 16
1 74 74 74








9 59 2200 467
4 6 6700 1792

2 36 1600 818



1 2300 2300 2300
Z 22 72 22



1 63 «5 63
| Wisconsin Study
No. Min Max Mean




23 0 120 27


















22 0 11300 1713







20 10 2828 24




Misc. Subtitle D
No. Min Max Mean























7 0 28800 5357 |
1




1





_
ORD/HWERL Study
|No. Min Max Mean
1 346 346 346
1 150 150 150
1 255 255 255
1 176 176 176




0000





3 14200 56000 33733
1 13800 13800 13800
2 12000 15500 13750
3 360 14400 6150
1 3020 3020 3020
1 7410 7410 7410
1 11500 11500 11500
2 3880 6200 5040
5 202 6020 1720
13 2400 110000 21590 j
12 110 47000 12300 j
8 3090 20600 11560 j
4 2400 49400 19900
4 3660 17000 8380
3 4180 21500 13990
2 1120 50100 25610
2 3600 39700 21650^
9 30 12000 3817
5 1660 6400 3740
1 770 770 770
1 9440 9440 9440
3 510 2610 1820
NEIC Study
JNo. Min Max Mean |

2 10 50 30






1 12 12 12





5 1200 820000 330840
0000
0000
0000


0 0 0 fl


18 140 140000 41434
10 12 46000 10087
11 1000 520000 1451B2





6 77 15000 3186


0000


-------
TABLE 5-8  ORGANIC COMPOUNDS FOUND IN RAW LEACHATE (CONTINUED)
(POLL.
«
31


64


21
R132
531



24






22
SB




516
514
564

545




550

POLLUTANT NAME
2,4-Dichlorophenol
2,4,6-Trimethyl-Phenol
Phenotpropanoic Acid
Pentach I oropheno I
2,2-Oimethyl-Propanoic Acid
4-Chloro-Benzoic Acid
2 , 4 , 6- T r i chl oropheno I
(2,4-Dichlorophenoxy)-Acetic Acid
2,4,5-Trichlorophenol
2,5-Oichlorophenol
1-Napthalene Carboxytic Acid
4-4'-Methylenebis-Phenol
2-Chlorophenol
4-<1,1-Diethyl-ethyl)-Benzoic Acid
4-Methoxy-Phenylacetic Acid
3,4-Dichloro-Benzoic Acid
3-<1,1-Dfmethylethyt)-Phenol
1,2-Dicarboxytic Acid Benzene
2,5-Dimethyl Phenol
4-Chloro-3-Methylphenol
4-Nitrophenol
Benzeneacetic Acid
Butanoic Acid, Ethyl Ester
Butanoic Acid, Methyl Ester
2-Methyl Hexanoic Acid
| EPA ITD STUDY
(No. Min Max Mean



0000















6 0 14 11
0000




Acetone |12 0 1671 253
2-Butanone |12 0 7855 1825
Benzyl Alcohol 9 0 63 16
4-Methyl-2-Pentanol
2-Hexanone
4-Methyl-2-Pentanol
2-Methyl Cyclopentanol |
1,1'-Oxybis(2-Methoxy-) Ethane |
2-Butoxy-Ethanol I
4-Methyl-2-P«nt«none 0000
2-(Z-Butoxy»thoxy)-Ethanol |
CLP Database
No. Min Max Mean
	


4 3 470 381

















2 4 350 177
1 23 23 23
1 12 12 12
1 480 480 480
4 630 850 727
2 960 2400 1680
1 3800 3800 3800
2 130 580 355





3 150 380 265

Wisconsin Study | Misc. Subtitle D
No. Min Max Mean | No. Min Max Mean



23 0 470 46
















1 17 17 17








































ORD/HWERL Study
No. Min Max Mean
4 87 2900 1529
1 5720 5720 5720
4 27 2230 890
1 1900 1900 1900
1 228 228 228
1 8220 8220 8220
1 3860 3860 3860
1 898 898 898
1 3440 3440 3440
1 2760 2760 2760
1 618 618 618
1 5540 5540 5540
1 1790 1790 1790
1 675 675 675
1 710 710 710
1 1210 1210 1210
1 525 525 525
1 33 33 33
1 318 318 318
1 36 36 36





0 0 0 0 | 13 344 77500 23200
| 12 62 42900 14710
j 6 1740 68000 24120
I
| 13 17 17200 4610
j 2 2450 33000 17720
j 2 1130 17800 9460
j 2 540 16600 8570
j 2 1560 3740 2650
NEIC Study
No. Min Max Mtan







2 80 440 260




3 10 130 62












15 100 1E+06 292273
12 6000 390000 190042


1 15000 15000 15000
4 3000 24000 12750


0000
|11 9 3790 915 |12 240 71000 16636
| 3 940 10800 5580 j

-------
TABLE 5-8  ORGANIC COMPOUNDS FOUND IN RAW LEACHATE (CONTINUED)
POLL.
#



54












68







66
71

69
19
43
17
70
67

510

POLLUTANT NAME | EPA ITD STUDY | CLP Database
|No. Min Max Mean |No. Min Max Mean
Cyclohexanone
Benzene-1,2-Dicarboxylic Acid Anhyd.
H,2,4-Trimethyl-1,3-Pentanediol
Isophorone
2,2-Dimethyl-1,3-Propanediol
Tributylester Phosphoric Acid
2-Ethyl-1-Hexanol
1-<2-Methoxy-1-Methylethoxy)-2-Propanol
1,2,4,6-Tetrathiepane
1-(2-Butoxyethoxy)-Ethanol
2,2'-Thiobis-Ethanol
4-Hydroxy-3Methoxy Benzaldehyde
1,3(2H)-Dione,1H-Isoindote
Napthol(1,8-CD)Pyran-1,3-Dione,1H,3H
Sulfonybis-Methane
2-Methyl-2,4-Pentanediol
Di-n-Butylphthalate
2- [2-(2-Ethoxy-ethoxy)Ethoxy] -Ethanol
9,10-Anthracenedione
Isoindole-1f3(2h)-Dionef3Af4,7,7A-Tetrah
Triphenyl-Phosphineoxide
2-Phenyl-2-01-Propan
1,2-Dicarboxylic Acid Anhydride Cyclohex
Alcanol
Bis(2-Ethylhexyl) Phthalate
Dimethyl Phthalate
Methyl Acetophenone
D-n-Octyl Phthalate
2-Chloroethyl Vinyl Ether
Bis(2-Chloroethoxy)Methane
Bis(Chloromethyl) Ether
Diethyl Phthalate
Butyl Benzyl Phthalate
2-Ethyl-1,4-Diroethyl-Benzene
Styrene
1,3-Diamino-4-Methyl Benzene
	


10 0 2396 255












0000







0000
0000


0000
0000
0000
8 0 38 14
0000






2 5 110 58












0000







Wisconsin Study | Misc. Subtitle D
No. Min Max MeanJNo. Min Max Mean



23 0 16000 970












23 0 150 25







14 12 3700 768 |23 0 150 33
2 26 26 26 |21 0 55 17
I
I
|19 0 1100 70
1 13 13 13 |20 0 25 11
1 250 250 250
7 25 84 45
23 0 330 101
0 0 0 0 |23 0 150 27
I
I
I



0000












0000







0000
0000





0000




| ORD/HUERL Study
|No. Min Max Mean
3 1650 3930 3067
3 1020 6720 3970
2 810 5490 3150
1 15000 15000 15000
2 588 2440 1510
1 18200 18200 18200
3 434 1860 960
2 112 1550 830
1 3020 3020 3020
2 1230 8860 5040
1 3930 3930 3930
1 770 770 770
1 1490 1490 1490
2 31 692 360
1 1560 1560 1560
1 2660 2660 2660
9 23 996 312
1 1560 1560 1560
1 750 750 750
1 1630 1630 1630
1 2390 2390 2390
2 226 402 314
1 1030 1030 1030
1 1020 1020 1020
1 1480 1480 1480
1 820 820 820
1 131 131 131
1 31 31 31



0000
0000
1 965 965 965
1 637 637 637
1 2480 2480 2480
| NEIC Study
j No. Min Max Mean
	 	 	 	 	
	 I
0000


6 10 1500 710












2 10 31 21







5 65 10000 2372
1 2200 2200 2200
0000
1 13 13 13



1 2100 2100 2100
1 490 490 490

3 180 43000 14627


-------
TABLE 5-8  ORGANIC CONFOUNDS FOUND IN RAW LEACHATE (CONTINUED)
|POU
*








585



91
112


2
515
8
571
509
506
513
936
554
523
18
580
578
502






POLLUTANT NAME
1,4-Diamino-Benzene
1, 2 -Oi ami no- Benzene
Benzamide
4-Hydroxy-4-Methyl -2-Pentanone
Ethanol
Bis(2-Chloroethoxy) Ethane
1,1'-Oxybis-2-Ethoxy Ethane
Methane, Thiobis
N.N-Ofemethyl Foramide
2,4-Diemethyl Heptane
2,3,5-Trimethyl Hexane
4-Ethyl-2-Methyl Hexane
Chlordane
PCB-1016
MCPP
TEPP
Acrolein
Ethyl Ether
1,2,4-Trichlorobenzene
0-Cresol
Alpha-Terpineol
N-Dodecane
P-Cymene
Thioxanthone
Vinyl Acetate
N-Tetracosane
Bis(2-Chloroethylether)
1,2,3,4-Diepoxybutane
2, 3-D ichloro-Ani 1 trie
2-Amino Naphthalene
2-Methoxy Aniline
2-Methyl Benzenesulfonamide
2-Pyridinanrin«
4-Ethyl-Morpholine
1,1.7-Trimethyl Bycyclo(2.2,1)Hept-2-ene
n-Alkanes(c>*
EPA ITD STUDY
No. Min Max Mean








0000





1666
2 665 1193 929
0000
12 0 1795 243
0000
9 25 12
8 0 121 36
8 0 62 17
8 0 17 11
9 0 286 50
12 0 17 11
8 0 153 28
8 0 12 10
10 0 338 43








CLP Database
No. Min Max Mean
	


2 710 76000 38355
1 42 42 42
1 13 13 13
1 460 460 460
1 47 47 47
1 15000 15000 15000
1 150 150 150
1 29 29 29
1 160 160 160
1 200 200 200
1 629 629 629




2 80 80 80
3 5 360 140
0000
1000














Wisconsin Study
No. Min Max Mean
















1 270 270 270



















Misc. Subtitle D
No. Nin Max Mean




































ORD/HWERL Study
No. Min Max Mean |
1 1940 1940 1940
1 835 835 835
1 1500 1500 1500















0000
10 94 24000 5300








1 1150 1150 1150
1 942 942 942
1 515 515 515
1 114 114 114
1 560 560 560
1 520 520 520
1 17300 17300 17300
1 9540 9540 9540
NEIC Study
No. Min Max Mean
















9 180 3E+06 541542
2 3000 14000 8500
3 580 29000 16193
6 14 21000 3582














I
I

-------
                                                             TABLE 5-8  ORGANIC COMPOUNDS FOUND IN RAW LEACHATE (CONTINUED)


















ON
W










POLL.
#






106
107

538


9
12
52
933
R071
921

48
533
505
80
547
3
527
104
102

POLLUTANT NAME
2,2,4,6,6-Pentamethyl-Heptane
Heptadecane
n-Alkanes(A)*
n-Alkanes(D)*
n-Alkanes(B)*
2-Propenyl idene-Cyclobutane
PCB-1242
PCB-1254
Tet rahydrof uran
1,2-Dibromoethane
2-Methyl-2-Butanol
2-Butanol
Hexach lorobenzene
Hexach loroethane
Hexach lorobutadiene
1,2,4,5-Tetrachlorobenzene
P-Chloroaniline
Pentac 1 orobenzene
Bromochloromethane
Bromodi ch loromethane
Carbon Disulfide
Dibenzofuran
Fluorene
Isobutyl Alcohol
Acrylonitrile
1,4-Dioxane
Gamma-BHC
Alpha-BHC
2-(2-Ethoxyethoxy) Ethanol
EPA ITD STUDY | CLP Database
No. Min Max Mean (No. Min Max Mean
	

























































Wisconsin Study | Misc. Subtitle D
No. Min Max MeanJNo. Min Max Mean


























































| ORD/HWERL Study
(No. Min Max Mean
1 4760 4760 4760
2 575 5440 3010
1 3380 3380 3380
1 3740 3740 3740
1 2700 2700 2700
1 75 75 75






0000
0000
0000




0000
0000
0000
0000





1 1210 1210 1210
NEIC Study
j No. Min Max Mean






3 300 240000 86767
1 700 700 700
8 4000 600000 137875
3 2200 19000 9733
1 71000 71000 71000
4 20000 490000 148000
1 10000 10000 10000
1 10000 10000 10000
1 30000 30000 30000
1 10000 10000 10000
1 1600 1600 1600
1 20000 20000 20000
1 1E+05 130000 130000
1 360 360 360
3 40 2500 1147
2 11 32 22
2 13 38 26
1 1000 1000 1000
2364
6 400 80000 23717
1 7800 7800 7800
1 5400 5400 5400
0000
NOTES:
(1)- All units in ug/l
(2)- Zero <0) indicates pollutant was analyzed for and not detected
(3)- No value indicates pollutant was not analyzed
(*). percent of Sites where pollutant was detected

-------
the  Water Program's analytical  methods.   Because  the data  were
collected  from several  sources,  there may  be a  few samples  of
leachate from hazardous waste landfills, either active or inactive,
included  in  Table  5-8.   It also is possible that RCRA  analytical
methods may  have been used for  a  few samples; however, the  vast
majority  of  the  leachates  are from Subtitle  D  facilities and  were
analyzed  using  the  Water Program  methods.    The  data from the
ORD/HWERL and  NEIC studies  in Table 5-8  present  the   organic
compounds  found  in  solely  hazardous waste  (Subtitle C)  landfills,
using the RCRA analytical methods.  Table 5-9 is a composite of the
6 studies  listed in Table  5-8.

     According to the data in Table 5-8, the  toxic organic  portion
of the ORD/HWERL leachates were  composed primarily of  base/neutral
extractable  compounds and  organic acids, both in terms  of the
number  of  compounds  and  their  concentrations,   although  some
volatile  compounds were found at very high  concentrations.  The
Wisconsin  leachates contained primarily  volatile compounds  (both
halogenated   and  aromatics)  as  did  the  leachates  from  the
miscellaneous  Subtitle  D landfills;  however, the predominance  of
volatile  compounds  in the  results of these two  studies  may be due
to analytes  dominated by volatile compounds.   Both the CLP  data
base and  the EPA-ITD study leachates showed  a fairly even  mix  of
volatile, base/neutral extractable, and acid extractable compounds.
Although  the  list  of analytes  for  the  EPA-ITD  study leachates
included  all of the Appendix IX organics,  few organic compounds
were found and at  relatively  low concentrations.   The  NEIC study
leachates  were evenly divided between volatile and  base/neutral
organic compounds.

     One hundred and sixty-two organic compounds were  found in the
ORD/HWERL and NEIC studies, which sampled hazardous waste landfill
leachates  using  RCRA analytical methods,  compared to  97  organic
compounds in the Subtitle D landfill  leachates  using Water  Program
analytical methods.   The  concentrations  of  individual compounds
also were significantly higher in the hazardous landfill  leachates.
This suggests that  leachates from hazardous waste landfills  contain
more toxic organic compounds and  at  higher concentrations  than
Subtitle  D landfill  leachates.    However,  the use of different
analytical methods also may have contributed to the difference  in
analytical results.  Another  factor  is that  the list of analytes
differed for each study;  however, the EPA-ITD study, which used the
most extensive list of  analytes,  found both  the fewest  organic
compounds in the leachates and some of the lowest  concentrations.

     Table 5-10  lists the most frequently  found organic compounds
in leachates  (i.e., those  found in  at  least  50  percent  of the
leachates sampled).  These data show that approximately 25 toxic
organic  compounds  are  found frequently  in  landfill  leachates.
Three compounds  (i.e.,  methylene chloride, toluene,  and benzene)
were found in 50 percent or more of the leachate samples from  four
or more of the studies reported  in Table 5-8.

                                64

-------
TABLE 5-9   ORGANIC COMPOUNDS  FOUND  IN RAW  LEACHATE
               COMPOSITE OF  DATA  SOURCES
POLL.
#
44
25
11
87
23
7
10
13
27
85
30
26
6
14
32
20
16
552
R138
88
15
46
45
R366
29
50

86
HC250
55
4
38
V074
904

81

77


56

78
1
39
84
72
POLLUTANT NAME
Methylene Chloride
Dichlorobenzene
1, 1, 1-Trichloroethane
Tr ichl or oethy 1 ene
Chloroform
Chlorobenzene
1 , 2-Dichloroethane
1, 1-Ddichloroethane
1 , 4 -Dichlorobenzene
Tetrachloroethylene
Trans, -1 , 2-Dichloroethylene
1 , 3-Trichlorobenzene
Carbon Tetrachloride
1, 1, 2-Trichloroethane
1 , 2 -Dichloropropane
2-Chloronapthalene
Chloroethane
Trichlorofluoroethane
1 , 3-Dichloropropylene
Vinyl Chloride
1,1,2, 2-Tetrachloroethane
Methyl Bromide
Methyl Chloride
Fluorotrichloroethane
1 , 1-Dichloroethene
Dichlorodifluoroethane
Chloromethyl-Oxirane
Toluene
Total Xylenes
Naphthalene
Benzene
Ethylbenzene
Trimethyl Benzene (Isomer)
2-Methylnaphthalene
1,2, 3 -Trimethyl Benzene
Phenanthrene
1 -Ethyl -2 -Methyl Benzene
Acenaphthylene
Tetramethyl Benzene , Isomer
Propyl Benzene
Nitrobenzene
1,3-Dimethyl benzene
Anthracene
Acenaphthene
Fluoranthene
Pyrene
Benzo (a) Anthracene
OVERALL-COMPOS ITE
Min. Max. Mean
0 620000
0 46000
0 100000
0 300000
0 55000
0 70000
0 57000
0 6300
0 9000
0 210000
0 6900
0 990
0 70000
0 70000
0 260
0 46
0 860
0 110
0 30
0 2700
0 500000
0 170
0 170
11 33
0 380
0 369
0 100
0 510000
0 370000
0 35000
0 6900
0 100000
143 300
15 3400
2240 2240
0 300
346 346
0 150
255 255
176 176
0 120
4600 4600
0 25
0 45
0 60
0 53
0 16
21673
9191
2955
5124
2538
1724
5433
355
1501
3947
390
285
5278
7184
84
23
31
19
11
179
27417
57
57
19
96
189
50
8393
16916
1323
508
3133
222
952
2240
92
346
49
255
176
1 *%
12
4600
10
23
*l f\
10
13

                    65

-------
TABLE 5-9
ORGANIC COMPOUNDS FOUND IN RAW LEACHATE
COMPOSITE OF DATA SOURCES (CONTINUED)
POLL.
#
74
75
76
557

569



930


65
944
943




947
34




31


64


21
R132
531



24






22
58
POLLUTANT NAME
Benzo (b) Fluoranthene
Benzo (k) Fluoranthene
Chrysene
Aniline
N,N-Dimethyl Acetamide
4-Chloroaniline
1-Methy 1-2 -Pyrrol idinone
Isoquinoline
Azepin-2 -One , Hydro- , 2H-
Pyridine
2-Chloro-Pyridine
4 -Methyl Benzenesulfonamide
Phenol
4 - ( P-Cresol ) Methy Iphenol
Benzoic Acid
Butanoic Acid
2-Methyl-Propanoic Acid
Pentanoic Acid
Alkanoic Acid
Hexanoic Acid
2 , 4-Dimethylphenol
Phenylacetic Acid
4- (Methylthio) -Phenol
Octanoic Acid
2 -Methyl -Butanoic Acid
2 , 4-Dichlorophenol
2,4, 6-Trimethyl-Phenol
Phenolpropanoic Acid
Pentachlorophenol
2,2-Dimethyl-Propanoic Acid
4-Chloro-Benzoic Acid
2,4, 6-Trichlorophenol
( 2, 4-Dichlorophenoxy) -Acetic Acid
2,4, 5-Trichlorophenol
2 , 5-Dichlorophenol
1-Napthalene Carboxylic Acid
4-4 ' -Methylenebis-Phenol
2-Chlorophenol
4-(l,l-Diethyl-ethyl) -Benzoic Acid
4-Methoxy-Phenylacetic Acid
3,4-Dichloro-Benzoic Acid
3- ( 1 , 1-Dimethylethyl ) -Phenol
1,2-Dicarboxylic Acid Benzene
2 , 5-Dimethyl Phenol
4 -Chloro-3 -Methy Iphenol
4 -Ni trophenol
OVERALL-COMPOSITE
Min . Max . Mean
0
0
0
0
0
0
0
3020
7410
0
3880
202
0
0
1000
36
3660
4180
1120
0
0
1660
770
0
63
87
5720
27
0
228
8220
3860
80
3440
2760
618
5540
10
675
710
1210
525
33
318
0
0
11
11
16
820000
13800
15500
14400
3020
7410
11500
6200
6020
140000
47000
520000
49400
17000
21500
50100
39700
15000
6400
770
9440
2610
2900
5720
2230
1900
228
8220
3860
898
3440
2760
618
5540
1790
675
710
1210
525
33
318
36
17
6
6
8
91162
6900
6875
3075
3020
7410
5750
5040
1720
11760
6045
78371
10359
8380
13990
25610
7983
1410
3740
770
4720
942
1529
5720
890
582
228
8220
3860
579
3440
2760
618
5540
926
675
710
1210
525
33
318
24
9
                           66

-------
TABLE 5-9
ORGANIC COMPOUNDS FOUND IN RAW LEACHATE
COMPOSITE OF DATA SOURCES  (CONTINUED)
POLL.
#




516
514
564

545




550




54












68







66
71

69
19
43
17
POLLUTANT NAME
Benzeneacetic Acid
Butanoic Acid, Ethyl Ester
Butai}oic Acid, Methyl Ester
2 -Methyl Hexanoic Acid
Acetdne
2-Butanone
Benzyl Alcohol
4-Methyl-2-Pentanol
2-Hexanone
4-Met3hyl-2-Pentanol
2 -Methyl Cyclopentanol
l,l'-Oxybis(2-Methoxy-) Ethane
2 -Butoxy-Ethanol
4 -Methy 1-2 -Pentanone
2- (2-Butoxyethoxy) -Ethanol
Cyclohexanone
Benzene-l,2-Dicarboxylic Acid Anhyd.
2,2,4 -Trimethyl-1 , 3-Pentanediol
Isophorone
2,2-Dimethyl-l, 3-Propanediol
Tributylester Phosphoric Acid
2-Ethyl-l-Hexanol
l-(2-Methoxy-l-Methylethoxy) -2-Propanol
1,2,4, 6-Tetrathiepane
1- (2-Butoxyethoxy) -Ethanol
2,2' -Thiobis-Ethanol
4-Hydroxy-3Methoxy Benzaldehyde
1,3 (2H) -Dione, IH-Isoindole
Napthol (1, 8-CD) Pyran-1, 3-Dione, 1H, 3H
Sul f onyb i s -Methane
2-Methyl-2 , 4-Pentanediol
Di-n-Butylphthalate
2 - [ 2 - ( 2 -Ethoxy-ethoxy ) Ethoxy ] -Ethanol
9 , 10-Anthracenedione
Isoindole-1, 3 (2h) -Dione, 3A, 4,7, 7A-Tetrah
Triphenyl-Phosphineoxide
2-Phenyl-2-01-Propan
1,2-Dicarboxylic Acid Anhydride Cyclohex
Alcanol
Bis(2-Ethylhexyl) Phthalate
Dimethyl Phthalate
Methyl Acetophenone
D-n-Octyl Phthalate
2-Chloroethyl Vinyl Ether
Bis ( 2 -Chloroethoxy) Methane
Bis(Chloromethyl) Ether
OVERALL-COMPOSITE
Min. Max. Mean
4
23
12
480
0
0
0
130
17
2450
1130
540
0
0
940
0
1020
810
0
588
18200
434
112
3020
1230
3930
770
1490
31
1560
2660
0
1560
750
1630
2390
226
1030
1020
0
0
0
13
0
0
0
350
23
12
480
1000000
390000
68000
580
17200
33000
17800
16600
3740
71000
10800
3930
6720
5490
16000
2440
18200
1860
1550
3020
8860
3930
770
1490
692
1560
2660
996
1560
750
1630
2390
402
1030
1020
10000
2200
131
31
1100
25
250
177
23
12
480
63291
52064
9312
355
9805
15235
9460
8570
1325
4454
5580
1534
3970
3150
2832
1510
18200
960
830
3020
5040
3930
770
1490
360
1560
2660
60
1560
750
1630
2390
314
1030
1020
776
511
66
22
35
8
125
                      67

-------
TABLE 5-9
ORGANIC COMPOUNDS FOUND  IN  RAW LEACHATE
COMPOSITE OF DATA SOURCES  (CONTINUED)
POLL.
#
70
67

510









585



91
112


2
515
8
571
509
506
513
936
554
523
18
580
578
502











POLLUTANT NAME
Diethyl Phthalate
Butyl Benzyl Phthalate
2 -Ethyl-1, 4 -Dimethyl -Benzene
Styrene
l,3-Diamino-4-Methyl Benzene
1 , 4-Diamino-Benzene
1 , 2-Diaxnino-Benzene
Benzamide
4 -Hydroxy-4 -Methyl -2 -Pentanone
Ethanol
Bis(2-Chloroethoxy) Ethane
1, l'-Oxybis-2-Ethoxy Ethane
Methane, Thiobis
N,N-Diemethyl Foramide
2 , 4 -Diemethyl Heptane
2,3, 5-Trimethyl Hexane
4-Ethyl-2-Methyl Hexane
Chlordane
PCB-1016
MCPP
TEPP
Acrolein
Ethyl Ether
1,2, 4-Trichlorobenzene
0-Cresol
Alpha-Terpineol
N-Dodecane
P-Cymene
Thioxanthone
Vinyl Acetate
N-Tetracosane
Bis (2-Chloroethylether)
1,2,3, 4-Diepoxybutane
2 , 3-Dichloro-Aniline
2-Amino Naphthalene
2-Methoxy Aniline
2 -Methyl Benzenesulfonamide
2-Pyridinamine
4 -Ethyl -Morphol ine
1, 1,7-Trimethyl Bycyclo(2 , 2 , l)Hept-2-ene
n-Alkanes(c) *
2,2,4,6, 6-Pentamethyl-Heptane
Heptadecane
n-Alkanes(A) *
n-Alkanes(D) *
n-Alkanes (B) *
OVERALL-COMPOSITE
Min . Max . Mean
0
0
965
180
2480
1940
835
1500
710
42
13
460
47
0
150
29
160
200
629
6
665
0
0
0
5
0
0
0
0
0
0
0
0
1150
942
515
114
560
520
17300
9540
4760
575
3380
3740
2700
2100
490
965
43000
2480
1940
835
1500
76000
42
13
460
47
15000
150
29
160
200
629
6
1193
3000000
14000
29000
24000
121
62
17
286
17
153
12
338
1150
942
515
114
560
520
17300
9540
4760
5440
3380
3740
2700
377
103
965
7632
2480
1940
835
1500
38355
42
13
460
47
7500
150
29
160
200
629
6
929
180604
4372
4068
2259
18
9
11
50
11
28
10
43
1150
942
515
114
560
520
17300
9540
4760
3010
3380
3740
2700
                       68

-------
         TABLE 5-9
ORGANIC COMPOUNDS FOUND IN RAW LEACHATE
COMPOSITE OF DATA SOURCES (CONTINUED)
POLL.
#

106
107

538


9
12
52
933
R071
921

48
533
505
80
547
3
527
104
102

POLLUTANT NAME
2 -Propeny 1 idene-Cyclobutane
PCB-1242
PCB-1254
Tetrahydrofuran
1 , 2-Dibromoethane
2-Methyl-2-Butanol
2-Butanol
Hexachlorobenzene
Hexachl or oethane
Hexachlorobutadiene
1,2,4, 5-Tetrachlorobenzene
P-Chloroaniline
Pentaclorobenzene
Bromochloromethane
Bromodichloromethane
Carbon Disulfide
Dibenzofuran
Fluorene
Isobutyl Alcohol
Acrylonitrile
1,4-Dioxane
Gamma-BBC
Alpha-BHC
2-(2-Ethoxyethoxy) Ethanol
OVERALL-COMPOSITE
Min. Max. Mean
75
300
700
4000
2200
71000
20000
0
0
0
10000
1600
20000
1E+05
0
0
0
0
1000
3
400
7800
5400
0
75
240000
700
600000
19000
71000
490000
10000
10000
30000
10000
1600
20000
130000
360
2500
32
38
1000
6
80000
7800
5400
1210
75
86767
700
137875
9733
71000
148000
5000
5000
15000
10000
1600
20000
130000
180
574
11
13
1000
4
23717
7800
5400
605
NOTES:

(1)- All units in ug/1
(2)- Zero  (0) indicates pollutant was analyzed for and not detected
(3)- No value indicates pollutant was not analyzed
(*)- Percent of Sites where pollutant was detected
                                69

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            TABLE  5-10.   MOST FREQUENTLY FOUND ORGANIC
                      COMPOUNDS IN LEACHATES
                                 No,
Pollutant
                   ORD/HWERL
Detects/No.
 Wisconsin
  Study
Samples(1)

EPA-ITD     NEIC
Methylene Chloride
Toluene
Benzene
13/13
13/13
12/13
20/24
22/24
18/24
4/12
5/12
2/12
11/13
16/18
12/18
Ethylbenzene               10/13

Phenol                     13/13
Acetone                    13/13
Butanone, 2-               12/13
Methyl-2-Pentanone, 4-      11/13
Trichloroethene            11/13
Total Xylenes              11/13

Hexanone, 2-                13/13
Methylphenol, 4-           12/13
O-Cresol  (2-Methylphenol)   10/13
Chloroform                 10/13
Dimethylphenol,2,4-         9/13
Di-N-Butyl Phathalate        9/13
Benzoic Acid                 8/13
Tetrachloroethylene          7/13
Diethyl Phthalate            0/13
Trans-l,2-Dichloroethylene   5/13
Dichloroethane, 1-1          4/13
Alpha-Terpineol
Isophorone                   1/13
Bis(2-Ethylhexyl) Phthalate  1/13
Chlorobenzene                6/13
                                  14/24

                                  17/24



                                  12/24
                                   6/24
                                   2/24
                                   4/24

                                   9/24
                                  17/24
                                  14/24
                                  14/24

                                  12/24
                                   6/24
                                   5/24
              4/12

              0/12
              3/12
              4/12
              0/12
              0/12
               0/12

               1/12
               0/12
               0/12
               0/12
               0/12
               0/12
               1/12
               2/12
               1/12
               4/12
               5/12
               0/12
               0/12
           13/18

           18/19
           14/16
           11/15
           16/20
           12/18
            8/10
             6/8
             4/5
             1/1
            6/15
             1/6
            9/19
             2/4
             2/8
             3/9
             3/6

            3/17
             1/7
             4/8
NOTE:
(1)
Data shows the pollutant frequency of occurrence,  the number
of times the pollutant was detected per  the number of samples
for which that pollutant was analyzed.  Dashes (-) mean either
the pollutant was not analyzed for or data was  not available
for this analysis.  Sampling data used  to  prepare  this table
are contained in Appendix A.
                                  70

-------
     The organic compounds found at the highest concentrations in
each study are  summarized in Table 5-11.   The NEIC and ORD/HWERL
lists are  composed of compounds  found in concentrations greater
than 100,000 jug/1  and 20,000 ng/1, respectively,  while the other
studies list compounds found in concentrations greater than 1,000
Mg/1.  The compounds with the highest concentrations  (i.e., in the
ORD/HWERL  and  NEIC  studies)  include  volatiles,  base/neutral
extractables, and acid extractables.  With the exception of phenol
and  isophorone, all  of  the  high-concentration compounds  in the
Wisconsin study are volatile chlorinated compounds.  This analysis
shows that at certain landfills, extremely high concentrations of
toxic materials can be expected in the leachate.


5.2.3  Leachate Flow  Generation Rates

     Numerous  studies have  attempted  to correlate the  rates of
leachate generation to landfill size  (volume  of wastes or surface
acreage),   climatic  factors  (net   precipitation) ,   geographic
location, and landfill design.  Generally,  these efforts have been
unsuccessful as is demonstrated by data from the Wisconsin Study
presented in Table 5-12,  and as illustrated in Figure 5-1.

     Studies  indicate that  leachate generation rates  at a given
landfill vary  greatly from  day to day,  primarily due to weather
conditions.   One  landfill with  flow monitoring reported volumes
ranging from 800 to 70,000 gallons per day (gpd) .  Such variations
coupled with the  lack of flow monitoring at most landfills makes
any estimate of leachate volumes difficult.  In lieu of predictions
based on landfill  size,  actual leachate collection ranges from 0
to 94,000  gpd.   Volumes  less than 100 gpd are insignificant and
probably  represent intermittent  flows.    Two landfills reported
leachate rates  of  less  than  1,000 gpd (0 and 270 gpd).  If these
low  values  are eliminated,  26,500 gpd is the calculated average
leachate generation rate.  Since these volumes generally  are based
on  estimates  rather than   actual  measurements,  30,000  gpd was
assumed to be the average leachate  generation rate for an  "average"
landfill.
 5.2.4  Summary

     In  summary,  the  following  observations can  be made  about
 landfill leachate:


          Landfill  leachates can contain very high concentrations
           (>100,000 /ig/1)  of toxic organic compounds.

          The  analytical  methods used  to identify  and  quantify
          organic pollutants in  leachate may have an effect on the
          quantification of the  organics found.

                                     71

-------
                TABLE 5-11.  ORGANIC COMPOUNDS  FOUND AT  THE
                     HIGHEST CONCENTRATIONS IN LEACHATE
ORD/HWERL Study
 (cone. > 20,000 M9/1)
NEIC Study
(cone.  >  100,000
                             CLP Database
                             (cone.  >  1,000 M9/1)
Phenol
Methylphenol, 4-
Benzoic Acid
Butanoic Acid
Pentanoic Acid
O-Cresol  (2-Methylphenol)
Alkanoic Acid
Hexanoic Acid
Acetone
Butanone, 2-  (MEK)
Benzyl Alcohol
Pentanol, 4-Methyl,2-
Methylene Chloride
Dichlorobenzene,  1,2-
Trichloroethane,  1,1,1-
Toluene
Aniline
Phenol, 2,6-bis(l,l-
   dimethyl-ethyl)-4-
   Methyl-
Trichloroethane, 1,1,1-
Tetrachloroethane, 1,1,2,2-
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
Trichloroethene
Tetrahydro furan
Butanone, 2- (MEK)
Total Xylenes
Acetone
Acrolein
Butanol, 2-
Phenol
Benzoic Acid
Aniline
PCB 1242
Bromochloromethane
                             Phenol
                             Methylphenol, 4-
                             Butanoic Acid
                             Hexanoic Acid
                             Butanone, 2-  (MEK)
                             Benzyl Alcohol
                             Bis(2-Ethylhexyl)
                                Phthalate
                             Hydroxy-4-Methyl -
                                2-Pentanone, 4-
                             Methylene Chloride
                             Toluene
                             Total Xylenes
                             Benzene, 1,3-
                                Dimethyl
                             Formamide, N,N-
                                Dimethyl
EPA-ITD Study
(cone. > 1000 M9/1)
Wisconsin Study
(cone. > 1000
                             Misc. Subtitle D
                              (cone. >  1000 M9/1)
Acetone
Butanone, 2-  (MEK)
Isophorone
Diethyl Ether
Methylene Chloride
TEPP
Ethyl Ether
Phenol
Isophorone
Chloroethyl Vinyl Ether, 2-
Methylene Chloride
Trichloroethane, 1,1,1-
Trichloroethene
Chloroform
Dichloroethane, 1,2-
Dichloroethane, 1,1-
Trans-l,2-Dichloroethene
Toluene
Benzene
Ethylbenzene
                             Phenol
                             Methylene  Chloride
                                     72

-------
              TABLE 5-12.  LEACHATE  GENERATION WISCONSIN STUDY
                                               Leachate Removal
                               Landfill Size        Rate
Landfill Type     Landfill  ID     (acres)        (gal/acre/day)     Qal/Landfill


Nat. Attenuation       2680           49                0                    0

Zone-of-Saturation      572           82             351               28,782
                       611           94             1000               94,000
                      1099           96             387               3^,152
                      1678          166             287               47,642
                      2484           47             304               14,288
                      2822           18               15                  270

Clay-lined             2569           30               88                2,640
                      2821           24             215                5,160
                      2892           10             176                1,760
                      2895           29             204                5,91f?

Retrofit                652           38             875               33,250
                                      73

-------



« 	
(0 •*•
tt Q
(0 "-
§<£
C Q)
* 0
Leachate 1
(Gallon//*



1,000-
900-
800-


700-
600-
500-
400-
300-
200-
100-
n
•
.






*
.
• ^
in on on A n en en ~tr\ on on 1 nn 1 1 n 1 on i on i -in 1 en i/?n nn
                     Landfill Size (Acres)

Figure 5-1. Leachate Flow Rates in Wisconsin
      (Source: Wisconsin Study, Ref. 7)

-------
          Raw leachates are  characterized by high concentrations
          of BOD5, COD, and TOC.

          Volatile  organics  frequently  are  found  in  leachates,
          while nonvolatile compounds,  if present, are not readily
          detected.

          Hazardous waste landfill leachates appear to contain more
          toxic organic  compounds  than  leachate  from  Subtitle  D
          landfills, but  this  observation may  be  due  to the list
          of analytes and/or analytical methodology problems.  In
          terms of COD and  TOC, however,  there  is no apparent
          difference  between  hazardous  waste  and  Subtitle  D
          landfills.

          Leachate flow rates vary widely due, in part, to climatic
          and geological  conditions,  but are  not related  to the
          size of  the  landfill. An average  leachate  flowrate is
          estimated to be 30,000 gpd for an "average" landfill.

          Leachates  generally  contain  high  concentrations  of
          aluminum,  iron,  zinc, manganese, and boron,  while the
          concentrations of toxic metals vary from below detection
          to over 100 mg/1.
5.3  INCINERATOR SCRUBBER WASTEWATERS
5.3.1  Sources of Incinerator Scrubber Wastewater Data

     The characterization of raw incinerator scrubber wastewaters
is  based solely  on  the data  obtained  from  the EPA-ITD  study
sampling efforts.  The EPA-ITD study sampled scrubber wastewaters
at two incinerators burning RCRA wastes and one  incinerator burning
both Toxic  Substances Control Act  (TSCA)-regulated  (PCB)  wastes
and RCRA wastes.   Data listings for  each facility are presented in
Appendix B.


5.3.2  Pollutants in the Incinerator Scrubber Wastewaters


5.3.2.1  Conventional and Nonconventional  Pollutants

     Chemical  characteristics  of   raw  scrubber wastewaters  are
partially  a  function  of  the  operation  of  the  scrubber  water
system.  Manufacturers of wet scrubbers indicate that the amount
of scrubber water that can  be recirculated depends on the amount
of  solids  being removed from the  gas stream.   In one  type of
scrubber operation,  TSS  is  maintained between  6,000  and 10,000
ppm, or TDS less than  10 percent.   Ammonia often is added to the

                                75

-------
recirculating water to neutralize  the  acids from the gases being
scrubbed.  At other operations,  scrubber effluent is treated using
lime precipitation  prior  to recycle.   This  results  in a low TSS
concentration in the recirculating scrubber water.

     These two different  types  of  operations result in different
chemical characteristics of  raw scrubber wastewaters, as summarized
in  Table  5-13 and  presented  in Appendix B.   TSS concentrations
range  from  2 to  58,000  mg/1;  the  higher  concentrations  were
associated with systems that operated without lime precipitation.
Ammonia concentrations range  from  0.1  to  3,100 mg/1.   The higher
concentrations were the result  of  ammonia used to neutralize the
acids. The pH of most raw scrubber wastewaters is low due to the
hydrogen chloride gases generated by burning wastes and removed by
the wet scrubbers.


     High TDS and  chlorides are characteristics of  all scrubber
wastewaters.  The high  TDS   is  caused  by  the  removal  of gases
containing  chloride and  SO2  (producing  sulfate in  water),  the
addition of chemicals to neutralize the acids in the stack gases,
and the dissolution of solids in the  particulates removed by the
scrubbers.
5.3.2.2  Toxic Pollutants

     Tables  5-14  and  5-15  summarize  the  metals  and  organic
pollutants in raw scrubber wastewaters.  These data indicate that
scrubber wastewaters  contain high concentrations  of  metals,  but
few organic pollutants.


Metals

     Table 5-14  shows  that  scrubber  wastewaters can contain high
concentrations of aluminum, iron, lead, zinc, mercury, and copper
(i.e., 20,000 to  500,000 Mg/1)-  Manganese,  boron, molybdenum, tin,
titanium, and nickel occur in significant (over  1 mg/1) but lesser
concentrations.   Potential  sources of the metals  are the wastes
and waste  containers  being incinerated  and the  materials  that
comprise the incinerator and scrubbers.  The  presence of titanium,
which is a corrosion-resistant metal used in scrubber construction,
is one example.

     The metals concentrations are also a function of the operation
of  the  scrubber  water  system,  with  the  high  concentrations
occurring at the  facility that recirculates a high TSS  and  TDS load
in the water.  The data suggest  that  a  large  portion of the metals
are associated with the solids being  recirculated (i.e., metals
contained in  the fly ash), but  this may not be the  case. Since
this scrubber water is not  treated (i.e.,  chemical precipitation

                                76

-------
   TABLE 5-13.
CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS IN
     RAW SCRUBBER WASTEWATERS
Pollutant
         Range of Detected Pollutantm(2)

        Minimum        Maximum         Mean
BOD5
COD
TOC
TSS
TDS
Chloride
O&G
Ammonia-N
TKN
NO2 and N03-N
Fluoride
Sulfide
pH (S.U.)
Phenols
Cyanide
TVO
Calcium
Magnesium
Sodium
18
110
17
2
4,007
2,400
1.0
0.1
1.6
0.25
2.75
0.1
1.2
0.05
0.01
0.1
440
5.16
150
300
760
630
58,000
11,700
9,000
1.8
3,100
200
3.9
400
0.1
7.3
0.22
0.02
0.1
3,410
320
500
88
410
195
12,700
6,710
5,550
1.1
733
56
1.7
100
0.1
0.12
0.01
0.1
1,660
203
330
NOTES:

 (1)  All  concentrations  expressed  in mg/1,  except pH
     Units).
                                         (Standard
 (2)  Data presented are the results of the EPA-ITD sampling effort
     of three incinerator scrubber wastewaters.  All sampling data
     for these  three  facilities are contained in Appendix B.
                                77

-------
          TABLE  5-14.   METALS  IN  RAW  SCRUBBER WASTEWATER
Metal
Range of Detected Metal(I]

Minimum    Maximum      Mean
Percent of Samples
   Where Metal
   Was Detected
Aluminum
Iron
Manganese
Boron
Barium
Molybdenum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
2,130
3,400
269
260
190
130
28
6
<1
12
45
<4
84
88
0.26
78
<5
2
<10
<13
59
4
<10
350
170,000
520,000
12,000
18,000
6,000
12,000
4,420
3,460
14
2,000
2,800
860
23,000
75,000
318
8,300
13
58
17
4,900
8,300
110
42
660,000
48,100
164,000
3,420
4,980
2,070
3,580
1,500
1,040
4.2
600
970
282
6,430
21,200
71
2,310
6.6
35
11
1,580
2,790
46
18
159,000
100
100
100
100
100
100
100
100
67
100
100
67
100
100
100
100
20
100
17
83
100
100
33
100
NOTES:

(1)  All concentrations expressed in M9/1-

(2)  Data presented are the results of the EPA-ITD sampling effort
     of three incinerator scrubber wastewaters.  All sampling data
     for these three facilities are contained in Appendix B.
                                  78

-------
     TABLE  5-15.   ORGANICS IN RAW SCRUBBER WASTEWATER(l)(2)
                                                 Number of Samples
                                                  Where Compound
Compound                Concentration  (1)          Was Detected
Acetone
Benzene
Bromoform
Fluoranthene
N-Nitrosodi-N-Propylamine
Pyrene
Thioxanthone
65
61
15
109
907
326
4,067
1
1
1
1
1
1
1
NOTES:

 (1)  All concentrations expressed in

 (2)  Data presented are the results of the EPA-ITD sampling effort
     of three incinerator scrubber wastewaters.  All sampling data
     for these  three  facilities are contained in Appendix B.
                                   79

-------
and clarification) prior to recirculation,  a significant amount of
dissolved metals may accumulate in the scrubber water.


Organic Compounds

     The absence  of  all but a few organic pollutants in the raw
scrubber wastewaters is expected if the RCRA and TSCA  incinerators
are  achieving the  required destruction  levels.    The  TOC data
support the  relative absence of  organics  except at one facility.
In  this  facility,   which  recirculates  high  TSS  concentration
scrubber  water,  the  TOC  concentrations  are  relatively  high;
however, the high TOCs  may be  due to carbon  particles in the TSS
from  fly  ash  rather  than organic compounds,  because  carbon
particles  can produce  a  positive  TOC test.   None  of  the raw
wastewaters  were  analyzed for  dioxin and  furan  isomers,  but the
presence of  these toxic organics in the scrubber sludges suggests
their presence in the raw scrubber wastewaters.  Further discussion
of dioxins and furans is presented in Section 6.2.


5.3.3  Scrubber Wastewater Flow Rates

     Data  for scrubber  wastewater discharge  (i.e.,  blowdown from
the  recirculating  scrubber water system)   was compiled  from four
facilities  (three  facilities sampled during  the EPA-ITD sampling
program and  information obtained from a fourth facility during an
engineering  visit).   Manufacturers  recommended that  blowdown be
controlled  by the amount  of  TSS or TDS   in the  scrubber water.
However, the scrubber systems sampled during this study show a wide
range of wastewater blowdown rates and water used for  scrubbing as
shown in Table 5-16.

     These  data  show an  average  scrubber blowdown rate  of 1.76
gal/lb  of  waste  incinerated.  In addition to being affected by the
amount of fly ash particulates  (TSS) and acid  (as TDS)  removed from
the stack  gases,  the blowdown rate  depends  on the level  of TSS
maintained  in the  scrubber water  system (Section  5.3.2),  the
chemicals used for scrubber water treatment,  and the  operation of
the scrubber wastewater  (blowdown)  treatment  system, if  one is
in-place.

     Manufacturers' data compiled by Mitre Corporation (Ref.  9) for
hazardous waste incinerator types and capacities are summarized in
Table 5-17.

     The weighted average is 2,200 Ib/hour  or 53,000 Ib/day, based
on a  24-hour operating day-   Coupled with the average scrubber
wastewater blowdown rate (1.76  gal/lb waste), the average scrubber
wastewater discharge per facility is estimated to be  93,000 gpd.
                                80

-------
      TABLE 5-16.   SCRUBBER WASTEWATER SLOWDOWN RATES (1)
                                 Blowdown
            % of recirculating flow     gal/lb. waste incinerated
Site G
Site H
Site I
Site X
....
9.6
2.2
15
0.65
3.90
0.46
2.02
Note:     Sites  G,  H,  and  I  were sampled  during  the  EPA-ITD
          sampling  program.    An  engineering  site  visit  was
          conducted at Site X.
                                      81

-------
    TABLE 5-17.  SUMMARY OF HAZARDOUS WASTE INCINERATOR TYPES
                        AND CAPACITIES  (1)
Incinerator
Type
Liquid Injection
Fixed Hearth
Rotary Kiln
Fluidized Bed

Average or Median
Capacity
rib/hr)
1,600
810
1,600
31,000

Number of
Units
93
48
34
_5
180
NOTE:
(1)  Data supplied by Mitre Corporation (Reference 9).
                               82

-------
     Three of the  four facilities that provided data during this
study are large incinerators.  Their average flow is 350,000 gpd,
which is well above the projected  industry average of 93,000 gpd.


5.3.4  Summary

     In summary, the  following observations can be made about raw
incinerator scrubber  wastewaters:


          Chemical characteristics of  raw scrubber wastewater are
          partially a function  of the scrubber system operation.
          High  ammonia concentrations are found  in  systems that
          use ammonia to neutralize acids.  TSS concentrations are
          high  in  systems  that do  not  use lime precipitation.

          Raw  scrubber wastewaters are  characterized  by  low pH,
          high  TDS, and high  chlorides.

          Scrubber wastewaters  contain  high  concentrations  of
          metals.      The  metals  detected   at   the   highest
          concentrations   include  aluminum,  iron,  lead,  zinc,
          mercury, and copper.

          Scrubber wastewaters contain few organic pollutants.

          An average  scrubber wastewater discharge is estimated to
          be   93,000   gpd  based  on  flow  measurements  and
          manufacturers' data.
5.4  AQUEOUS HAZARDOUS  WASTE

     The  following  sections summarize  the  pollutants  found in raw
aqueous hazardous wastes.   Data were obtained from two sources, as
indicated in the summary tables.   Individual  listings of the data
are presented  in Appendix C.


5.4.1  Sources of Raw Waste Data

     The  primary source  for analytical data characterizing aqueous
hazardous wastes is  the 1986-87  EPA-ITD  study sampling effort.
Four  aqueous  hazardous  waste treatment  facilities were sampled
during this program.   The  aqueous treaters accepted  and treated
inorganic  industrial  wastes  (plating  baths,  pickle liquors);
organic  wastes  (food and  pharmaceutical  manufacturing,  solvent
reclaiming,  detergent manufacturing); oil wastes;  tank washings;
leachates (hazardous and Subtitle D landfills); brines; scrubber
wastewaters; miscellaneous  waste  acids;  and caustics.
                                83

-------
     The EPA-ITD study sampling data are supplemented by analytical
data obtained from two aqueous treaters sampled during an OSW study
to  support OSW's  Land  Disposal  Restriction  Rules.   While  the
EPA-ITD  study  analyzed  the wastewaters   for the  Appendix  IX
pollutants in addition to conventionals and nonconventionals, the
OSW samples were only  analyzed  for 15  toxic  metals,  29 volatile
organic compounds, 29 extractables,  and selected conventional and
nonconventional pollutants.   QA/QC data are  available  for both the
EPA-ITD and OSW sampling efforts.


5.4.2  Pollutants in the Raw Aqueous Hazardous Waste


5.4.2.1  Conventional and Nonconventional Pollutants

     Table 5-18  summarizes  the  conventional  and  nonconventional
pollutant  data  from  the previously discussed  sources.   The data
show that aqueous hazardous wastes contain high concentrations of
BOD5_, COD, and TOC (mean concentrations of BOD5_, COD, and TOC are
in the range  of  1,500 to  15,000  mg/1).   These data indicate that
these  facilities have  a wide range of concentrations  for these
pollutants.   In addition, the individual sample data presented in
Appendix C show  that the  concentrations of  these  pollutants vary
widely from day  to day. This is  due to variations in waste types
being processed by these facilities.

     The  fact that the raw  wastes  treated at aqueous  hazardous
treatment facilities are high-strength wastes  also is reflected in
the presence  of other  pollutants,  specifically TSS, TDS,  total
solids, ammonia, TKN, oil and grease,  and cyanides.  As with BOD5_,
COD, and  TOC, the concentrations of  these  pollutants are highly
variable, and the overall mean concentrations are high.


5.4.2.2  Toxic Pollutants

Metals

     Metals   data  for  the  raw  aqueous  hazardous  wastes  are
summarized   in  Table   5-19.     Like   the   conventional   and
nonconventional pollutant data,  the metals data show a wide range
of concentrations  among facilities  and from  day  to day.  Metals,
including  aluminum,  iron, (Jaoron,  copper,   zinc,  chromium,  lead,
cadmium,  nickel,  and manganese,  were  found at concentrations as
high as 11,000 mg/1.  Copper,  chromium,  cadmium, lead, nickel, and
zinc  are  common metals  with  numerous  industrial  uses,  which
accounts for  their presence  in all  raw waste samples.  Aluminum,
iron,  boron,  and manganese  are  also present  in  many industrial
wastewaters.     Less  commonly used  industrial metals  such  as
beryllium, selenium, silver,  thallium,  tin,  vanadium,  cobalt,
arsenic,  and yttrium were found at lower concentrations.

                               84

-------
TABLE 5-18.  CONVENTIONAL AND NONCONVENTIONAL  POLLUTANTS  IN
           AQUEOUS HAZARDOUS WASTES - SUMMARY(1)


Pollutant
BOD5
COO
TOC
Total Solids
TDS
TSS
Chloride
O&G
Total Organic Hal ides
Ammonia(2)
TKN(2)
N02 and NOj-N
Fluoride
Sulfide
Phenols
Cyanide
Silica
TVO
Calcium
Magnesium
Sodium
NOTES:


Minimum
330
4,160
450
--
2,700
130
300
4.2
--
8.1
2.5

2.3

1.4
0.1
--

59
5.0
527

EPA-ITD

Maximum
3,720
14,100
1,600
--
Study

Mean
2,000
8,360
985
--
70,400 23,400
9,240
11,500
1,390
--
1,000
1,210

500

18.7
5.0
--

711
136
6,500

(1) All concentrations expressed in mg/l
(2) Evidence of the
analytical problems
1,570
4,720
385
--
475
382

138

8.64
1.18
--

389
48
2,270

, except
discussed

No. of


Samples Minimum
8
8 11
7
200
8 10
8 46
8
8 2
--
8
8

8

8
8
--

8
8
8

total organic
in Section 5.

,000
52
,000
,000
,000
--
,600
0
20
--
--
19

--
<20
0.4
--
--
--
~ ~

OSW Study

Overa 1 1

Maximum Mean
..
70,000 39
19,000 4
250,000 223
170,000 107
240,000 115
--
18,000 11
0.36
100
--
--
52

--
450
1.32
--
--
--
~ ~

ha I ides (weight %),
..
,300
,180
,000
,000
,000
--
,200
0
52
--
--
35

--
235
0
--
--
--
" ~

and
1 can be seen here were
No. of
Samples
._
3
14
3
3
3
--
3
.144 15
3
--
--
3

--
2
.81 3
--
--
--
~ ~

silica (weight

Mean
2,000
16,800
3,115
223,000
46,200
32,500
4,720
3,330
0.144
360
382

110

8.64
48
0.81

389
48
2,270

%).
ammonia is reported higher
No. of
Samples
8
11
21
3
11
11
8
11
15
11
8

11

8
10
3

8
8
8


than TKN.

-------
                  Table  5-19.   Metals in Aqueous Hazardous Wastes - Summary(1)
o\
Pollutant
Aluminuum
Iron
Manganese
Boron
Barium
Molybdenum
Antimony
Arsenic
Beryllium
Cadmium
Chromium, total
Chromium, hex.
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc

Minimum
730
3,780
380
8,800
205
608
22
<25
<1
16
108
--
<50
296
<200
1.1
252
<5
2.2
--
<40
<50
47
<10
334
EPA- 1 TO
Maximum
63,400
11,200,000
68,400
63,500
1,100
2,290
2,140
1,051
16
1,190
99,900
--
1,310
969,000
17,100
92
93,700
3,270
525
<10
3,520
2,280
641
430
6,570,000
Study
OSW Study
X
Mean Detected
(2) (3)
29,300
2,560,000
16,900
26,300
522
1,080
477
248
14
363
35,600
--
547
221,000
6,940
25
22,500
685
177
--
2,000
806
227
206
1,330,000
100
100
100
100
100
100
100
86
25
100
100
--
62
100
75
100
100
62
62
0
50
75
75
38
100
Minimum
--
--
<10,000
--
<10,000
--
--
3,900
12,000
50
--
72,000
1,100
--
4,300
--
--
--
--
--
--
--
3,900
Maximum
--
--
12,000
--
40,000
<1,000
<2,000
225,000
2,581,000
893,000
--
1,500,000
212,000
<1,000
16,330,000
<10,000
<2,000
<10,000
--
--
--
--
1,700,000
X
Mean Detected
(2) (4)
--
--
(5)
--
(5)
--
--
58,800
1,205,000
408,000
--
294,000
60,900
--
1,992000
--
--
--
--
--
--
--
194,000
--
--
8
--
8
0
0
53
100
100
--
100
67
0
100
0
0
0
--
--
--
--
100
Overall
No. of
Mean Samples
(6) (7)
29,300
2,560,000
16,900
26,300
1,800
1,080
4,870
248
14
29,600
798,000
408,000
547
269,000
25,000
25
1,307,000
685
177
0
2,000
806
227
206
589,000
8
8
8
8
9
8
9
6
2
16
23
12
5
23
16
8
23
5
5
0
4
6
6
3
23

-------
                  Table  5-19.   Metals in  Aqueous  Hazardous Wastes - Summary(1)   (Continued)


     NOTES:

     (1)     All concentrations expressed in fig/1.

     (2)     Mean of detected values; values reported less than  the detection  limit not included in mean calculation

     (3)     % detected in the EPA-ITD  Study based  on sampling data from four  sites (total of 8 samples).  All  sampling data are contained in Appendix C.

     (4)     % detected in the OSW Study was based  on sampling results from two facilities.  The number of samples for which a given pollutant was analyzed
            ranged from 12 to 15.  Sampling data are contained  in Appendix C.

     (5)     Mean not presented when the pollutant  was measured  at higher than the detection limit in only one  sample.

     (6)     The overall mean was calculated using  the mean concentrations from the two studies using the following formula:

            Overall mean =  Z (mean  x n)
                               Z n

     (7)     Total number of samples in the combined studies in  which the pollutant was detected.
00

-------
Organic Compounds

     Table 5-20 summarizes the organic pollutants  found in the raw
aqueous hazardous wastes.  Like the other pollutants, the organic
compounds are found in a wide range of concentrations and in many
cases, at  high concentrations.  Common  organic solvents  such as
acetone,  2-butanone  (MEK), methylene  chloride,  benzene, 1,1,2,2-
tetrachloroethane,  and   toluene  were  found  in  the  highest
concentrations.    These  compounds  were  also  among  the  most
frequently detected organic  pollutants  (i.e., found  in 38  to 75
percent  of  the samples  taken in  the HWT  study.    In addition,
several  extractable organics:  thioxanthone,  2-chloronaphthalene,
alpha-terpineol, phenol,  and 4-chloro-3-methylphenol,  were found
in high concentrations (i.e., as  high as 28,000 jug/I) , but usually
in  less  than  half  of  the samples.    The  most  commonly  found
extractable compound was di-n-butyl phthalate, which was detected
in 63 percent  of the  samples tested.  Phenol was  detected in two
of the three OSW study  samples,  but in  only two of eight EPA-ITD
study samples.


5.4.3  Aqueous Hazardous Waste Flow Rates

     Flow data for  aqueous hazardous waste  treatment facilities
were   compiled from  numerous sources.    The HWT  study sampling
efforts,  presampling  visits,  and telephone  contacts yielded flow
rates  from  12 facilities.  These  ranged from  13,600 to 117,000
gpd, with an average of 59,400 gpd.  The "1985 Survey of Selected
Firms  in  the  Hazardous  Waste  Management   Industry"   (Ref.  11)
indicated that 34  chemical/biological treatment facilities treated
1,567,000 wet metric  tons  of hazardous  wastes in  1985.  Assuming
300 days/year of operations and 8.34 Ib/gal,  the average flow rate
is  40,600  gpd.   If  these  two  estimates are  combined, a  flow
weighted average of  45,500 gpd is calculated  for a typical aqueous
hazardous waste treatment facility.


5.4.4  Summary

     In summary, the following observations can be made about the
toxic pollutants in  raw  aqueous hazardous wastes and industry flow
rates:
          Aqueous hazardous wastes contain high concentrations of
          BOD5,  COD,  and TOC.

          Both metals and organic compounds  were  found in a wide
          range of concentrations and,  in  some cases, at very high
          concentrations.
                                    88

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            TABLE 5-20.  ORGANIC POLLUTANTS  IN  AQUEOUS  HAZARDOUS WASTES - SUMMARY(1)
00

Pollutant Minimum
Volatiles
Acetone <50
Benzene <10
Butanone, 2- (MEK) <50
Carbon Tetrachloride <10
Chlorobenzene <10
Chloroform <10
Dichloroethane, 1,1- <10
Dichloroethane, 1,2- <10
Dichloroethene, 1,1- <10
Di ethyl Ether <50
Dibromoethane, 1,2- (EDB) <10
Ethyl benzene <10
Hexanone, 2- <10
Methylene Chloride <10
Tetrachloroethane,
1,1,2,2- <10
Tetrachloroethene <10
Toluene <10
Trans-1,2-Dichloroethene <10
Trichloroethane, 1,1,1- <10
Trichloroethane, 1,1,2- <10
Trichloroethene <10
Vinyl Acetate <10
Extractables
Alpha-Terpineol <10
Isophorone <10
N-Dodecane (N-C12) <10
EPA ITD
Maximum

1,719,690
17,171
156,973
329
650
1,151
839
263
1,517
81
20
934
200
4,094

108,716
3,043
115,068
190
4,163
332
5,060
814

5,701
2,372
47
Study
OSW Study Overall
Mean Detected
(2) (3)

254,177
2,241
48,225
54
94
285
150
62
198
54
11
378
57
1,388

13,635
407
16,281
55
1,063
52
673
111

1,446
501
19

63
75
63
25
25
38
25
38
13
13
13
63
25
75

38
25
75
38
75
25
63
13

38
38
13
Minimum Maximum Mean Detected Mean
(2) (4) (6)

22,000 (5) 33 228,380
2,241
48,225
54
94
<10 110 18 8 125
<10 340 64 27 98
62
198
54
11
<10 200 49 40 181
57
<10 63,000 6,875 20 4,966

13,635
<10 2,300 200 33 279
<10 2,300 298 47 6,110
<10 25 11 8 29
<10 9,400 1,182 40 1,139
<10 46 13 8 29
<10 1,100 123 20 333
111

1,446
501
19
No. of
Samples
(7)

9
8
8
8
8
20
20
8
8
8
8
20
8
23

8
21
22
20
22
20
21
8

4
6
4

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TABLE 5-20.  ORGANIC  POLLUTANTS  IN AQUEOUS HAZARDOUS WASTES - SUMMARY(1)  (CONTINUED)

Pollutant Minimum
N-Hexadecane (N-C16) <10
N-Docosane (N-C22) <10
Benzoic Acid <10
P-Cresol <10
0-Cresol <10
Thioxanthone <10
Di-N-Butyl Phthalate <10
Pentachlorophenol <50
Phenol <24
Chlorophenol, 2- <10
Chloronaphthalene, 2- <10
Chloro-3-Methylphenol, 4- <10
Benzyl Alcohol <10
Hexanoic Acid <10
Isobutyl Alcohol <10
Methyl Methacrylate <10
Bis (2-Ethylhexyl)
Phthalate <10
Fluorene <10
Naphthalene <10
Styrene <10
Diphenylhydrazine, 1,2- <10
Dini trotoluene, 2,4- <10
Bis (2-Chloroethyl) Ether <10
Diphenylamine <10
Hexachloro-1,3-Butadiene <10
Hexach I orobenzene <10
Hexach I oroe thane <10
Dichlorobenzene, 1,2- <10
Methylnaphthalene, 2- <10
EPA I TO
Maximum
2,969
5,056
1,129
64
1,703
28,625
1,059
117
4,442
10
16,480
3,397
2,601
2,443
187
12

380
20
285
1,003
26
192
1,391
22
599
14
132
106
2,444
Study
OSW Study
X X
Mean Detected Minimum Maximum Mean Detected
(2) (3) (2) (4)
869
1,019
540
24
222
7,996
220
67
1,560
10
3,519
1,322
795
928
35
10

129
13
75
224
19
57
286
13
157
11
41
34
358
25
13
25
25
13
25
63
13
75 3,900 4,400 4,150 67
13
25
25 -- 3,100 (5) 33
38
38
25
13

38
13
25
38
13
25
13
13
13
13
13
13
13
Overs 1 1
Mean
(6)
869
1,019
540
24
222
7,996
220
67
2,208
10
3,519
1,678
795
928
35
10

129
13
75
224
19
57
286
13
157
11
41
34
358
No. of
Samples
(7)
5
5
4
4
8
7
5
4
8
4
6
5
8
5
8
8

6
4
5
6
4
4
5
4
4
4
4
4
7

-------
     TABLE  5-20.    ORGANIC  POLLUTANTS  IN AQUEOUS  HAZARDOUS WASTES  - SUMMARY(1)   (CONTINUED)
   Pollutant
                                EPA ITD  Study
                       Minimum    Maximum
                                           Mean
                                           (2)
                                           Detected
                                             (3)
                                                                   OSW Study
Minimum   Maximum
                    Mean
                    (2)
Detected
  (4)
                                                                                                             Overall
Mean
(6)
No.  of
Samples
  (7)
N-Octadecane (N-C18)      <10         449       98       20
N-Decane  (N-C10)          <10         670      208       33
Butyl  Benzyl Phthalate    <10         785      165       20
Nitrophenol, 2-           <20         202       66       25
N-Nitrosodi-N-
  Butylamine              <10         200       37       14
P-Cresol                  <10          64       24       50
                                                                                                   98
                                                                                                  208
                                                                                                  165
                                                                                                   66

                                                                                                   37
                                                                                                   24
                                                      5
                                                      6
                                                      5
                                                      4

                                                      7
                                                      4
NOTES:

(1)

(2)

(3)

(4)


(5)

(6)
All concentrations expressed  in fig/1.

Mean of detected values;  values reported less than the detection limit not included  in mean calculation.

% detected in the EPA-ITD Study based on sampling data from four sites (total of 8 samples).  All sampling data are contained  in Appendix C.

% detected in the OSU Study was based on the sampling results from two facilities.  The number of samples for which a given pollutant was analyzed
ranged from three to fifteen.  Sampling  data are contained in Appendix C.

Mean not presented when the pollutant  was measured at higher than the detection limit in only one sample.

The overall mean was calculated using  the mean concentrations from the two studies using the following formula:

Overall mean = 2 (mean x  n)
                  2 n
(7)
Total  number of samples in the combined studies in which  the pollutant was detected.

-------
The metals found the most frequently and at the highest
concentrations were chromium, copper, nickel, zinc, iron,
aluminum, boron, and manganese.

The organics found the most frequently and at the highest
concentrations were industrial solvents.

The wide range of concentrations of the toxic pollutants
in the raw waste samples can  be attributed to the high
variability  of wastes  received  and  treated  by  these
facilities.

Flow rates at facilities treating aqueous hazardous waste
averaged 45,500 gpd.
                          92

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              6.   CONTROL AND TREATMENT TECHNOLOGIES
     This section discusses the control  and treatment technologies
employed in each  of  the hazardous waste treatment (HWT) industry
subcategories.  The information presented in  this  section has been
complied from several  sources.  The effluent and residuals data
corresponding to specific treatment systems were obtained from the
U.S.  Environmental  Protection  Agency   - Industrial  Technology
Division (EPA-ITD) study,  as  well as other EPA sampling efforts.
Discussions of other  treatment and disposal methods employed  by the
industry were obtained from presampling visits, telephone contacts,
and published reports.

     Because of the variability  in the  strength of the raw wastes
and  the long  detention times  of the  treatment  systems,  it  is
difficult to estimate percent pollutant reductions, especially with
only  two  consecutive  days  of  samples.  Therefore,   the  percent
reduction  data presented  in  this  section  cannot be considered
accurate.  Many data  pairs actually  showed negative removals.  In
these instances,  the  percent  removals were assumed to be zero.
6.1  LEACHATE TREATMENT

     Leachate   treatment   systems  are   composed   of   various
combinations of unit processes, each highly individualized to meet
the regulatory requirements imposed by the receiving Publicly-Owned
Treatment  Works  (POTW) or  the NPDES permitting  authority-   For
example,  some  POTWs  only  require  aeration  to oxygenate  the
leachate,  while  other POTWs  require,  in  addition  to aeration,
combinations  of  biological treatment,  air stripping,  and carbon
adsorption  prior  to  discharge.    These  extremes  reflect  the
diversity in approaches to  the treatment  of leachate found in the
HWT industry.


6.1.1  Sources of Data

     The  primary  source   of   data  regarding  leachate treatment
technologies and the  only source of effluent data is the EPA-ITD
study  effort,  which included  six  leachate treatment  facilities.
Telephone  contacts   supplied  information  on   other  discharge
technologies  such  as  recirculation,  solidification,  and contract
hauling.  Only facilities that provide  treatment  and discharge of
leachate actually were visited and/or sampled.
                                93

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6.1.2  Subtitle D and Subtitle C Facilities

     Little information  is  available at this  time regarding the
differences in  treatment technologies employed  for treatment  of
leachate from hazardous  versus  Subtitle  D landfills; however,  of
the 10 hazardous waste landfills for which information is available
(6 landfills from the EPA-ITD sampling program and 4 from telephone
contacts), 5 have on-site wastewater treatment plants, 3 contract
haul their leachate to a commercial  aqueous treater, 1 deep well
injects, and 1  solidifies and reburies the  leachate.   Of the 5
with  on-site wastewater  treatment systems,  two also  serve in a
commercial aqueous hazardous waste treater capacity.

     Discharge to a POTW  or hauling to a commercial  aqueous treater
are  the  primary  leachate management methods  for Subtitle  D
landfills.   As mentioned previously,  the  treatment technologies
employed by  those  discharging to  a  POTW range  from aeration  to
sophisticated  advanced  treatment  systems.    Specific  leachate
treatment systems, their technologies, and effluent quality will
be discussed in the following sections.


6.1.3  Preliminary Treatment


6.1.3.1  Treated Effluent Data
Conventional and Nonconventional Pollutants

     Three landfills  included  in the  EPA-ITD study provided only
aeration  of  their  leachate  prior to discharge  to POTWs.   The
landfills were  municipal  landfills and aeration  was  employed to
protect the sewers  from hydrogen sulfide  and methane gas buildup
rather than to provide biological treatment. Consequently, little
BODI5 and COD reduction were observed at two of the  facilities.  The
third facility has an aerated lagoon,  which provided a 45 percent
reduction in BOD5 and 50 percent reduction in COD.   Some TOC and
ammonia reduction was observed  in all  of the  systems.  The average
effluent concentrations from these three landfills are summarized
in Table 6-1.


Metals

     Aluminum,   iron,  manganese, boron,  and  zinc were  found in
concentrations higher than 1,000 ng/I  in the raw leachate feed to
the aeration ponds.  Mean reductions'  of  these metals ranged from
0 to 46 percent.  The metals showing  the highest average percent
reductions were iron, aluminum, and zinc.
                               94

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TABLE 6-1.  CONCENTRATIONS OF POLLUTANTS IN PRELIMINARY
     TREATMENT SYSTEM  (AERATED LAGOON) EFFLUENTS  -
                  LEACHATE SUBCATEGORY
Effluent Concentration
Pollutant Units
BODS
COD
TOC
TSS
Ammonia
TKN
Oil & Grease
Aluminum
Iron
Manganese
Boron
Zinc
Nickel
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Molybdenum
Titanium
Vanadium
Yttrium
Antimony
Arsenic
Mercury
Acetone
Alpha-Terpineol
Benzyl Alcohol
Bromoform
Diethyl Phthalate
Isophorone
Methylene Choride
Butanone, 2- (MEK)
Hexanone, 2-
Carbon Tetrachloride
Methyl Methane-
sulfonate
Dimethyl Sulfone
Benzene
Diethyl Ether
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Mg/i
Mg/l
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i

Mg/i
Mg/i
Mg/i
Mg/i
Minimum
180
992
270
16
39
50
4.
<100
10,700
5,130
1,220
338
67
153
<5
15
75
<25
<200
<100
<50
<50
<50
<20
45
<0.
<50
65
<10
<10
<10
<10
<10
<50
<10
<10

<10
<10
<10
<50
Maximum
2,520
7,860
3,670
3,080
197
301
1 498
1,720
205,000
19,300
5,070
3,660
298
271
<5
87
91
41
<200
<100
81
<50
<50
<20
56
2 <0.
7,772
367
64
62
26
245
17
6,600
57
23

557
12
<10
<50
Mean %
Mean Removal (1)
1,270
3,890
1,120
658
118
163
98
745
70,000
10,200
2,710
1,050
184
210
<5
45
83
28
<200
<100
55
<50
<50
<20
50
2 <0.2
2,564
154
24
19
14
70
11
2,070
18
12

119
10
<10
<50
15
18
18
23
25
19
44
46
45
22
19
39
13
24
(2)
37
20
1
(2)
(2)
15
13
5
(2)
23
(2)
29
6
0
0
8
51
64
49
0
0

0
0
27
60
                           95

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     TABLE 6-1.   CONCENTRATIONS OF POLLUTANTS IN PRELIMINARY
          TREATMENT SYSTEM (AERATED LAGOON) EFFLUENTS -
                LEACHATE SUBCATEGORY  (Continued)


                             Effluent Concentration      Mean  %
Pollutant           Units  Minimum   Maximum   Mean    Removal(1)
Ethylbenzene          »«/i       
-------
Organic Pollutants

     As discussed in Section 5,  there is  evidence to indicate that
the analytical methods used for the analysis of organic compounds
may not detect and identify and/or completely quantify many of the
Appendix IX organics. Whether this problem also occurs in leachate
after treatment is not known because there are  no treated leachate
data  from other  studies  for comparison.   However,  the  organic
compounds detected in treated leachate may represent only a portion
of the Appendix IX compounds actually present.

     Although  the   majority   of   the  toxic  organic  compounds
identified in the raw and aerated leachate were volatiles,  it is
difficult  to  determine the  extent of treatment provided  by the
aerated  lagoons.    The  reasons are again the variable influent
concentrations and the detention times, which make  it difficult to
pair treated and untreated concentrations. Table 6-1 presents the
average  effluent concentrations  for the  three  aerated lagoons.
Both acetone and 2-butanone are present in the  treated effluent in
concentrations exceeding  1,000 M9/1-

     In summary,  it  appears that  little  treatment is achieved in
preliminary  treatment  systems.    The   only  metals  that  show
significant reductions  in concentration  are  aluminum,  zinc,  and
iron.  This is a result of only limited precipitation/sedimentation
of the balance of metals occurring in the aerated lagoons.  Acetone
and 2-butanone are  present in  aerated lagoon effluents with mean
concentrations exceeding  of 1,000 /xg/l.


6.1.3.2  Residuals Data

     Table 6-2 summarizes data for metals and organics found in the
sludge  from the  one aerated lagoon at  which a sample could be
collected.  Aluminum and iron,  the metals with  the  highest percent
removals, were also  the metals with the highest concentrations in
the sludge.  Only one organic compound,   acetone,  was detected in
the sludge; however, only one sludge sample was collected compared
to six treated effluent  samples.    Therefore,  this single sludge
may not  be representative of organic compounds  found in aerated
lagoon sludges.


6.1.4  Biological Treatment
6.1.4.1  Treated Effluent Data

     One  facility  sampled  during  the  EPA-ITD  study  provided
biological  treatment  for  leachate.   The  raw  leachate  to this
activated sludge  system was  of  low strength  due  to dilution by
groundwater.

                                97

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TABLE 6-2.
CONCENTRATIONS OF POLLUTANTS IN PRELIMINARY TREATMENT
 SYSTEM SLUDGE - LEACHATE SUBCATEGORY(1)
Pollutants
Acetone
            Units(2)
             Mg/1
Sludge Sample
Aluminum
Barium
Boron
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Molybdenum
Nickel
Tin
Titanium
Zinc
Antimony
Arsenic
Mercury
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
4640
35
6
1
16
6
16
14,900
11
169
<5
21
7
317
225
<2
35
0.4
                                                      161
NOTES:
(1)   Preliminary treatment in the leachate subcategory is aerated
     lagoons.  Sludge sample collected from aerated lagoon.

(2)   Mg/kg reported on a wet sludge basis.
                                  98

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Conventional and Nonconventional Pollutants

     The activated sludge system included the addition of powdered
activated carbon.  No reduction in BOD5_,  COD, or TOG was observed.
The effluent BOD5 concentration averaged  39 mg/1,  as shown in Table
6-3.  Small reductions in the  ammonia and TKN concentrations were
observed.

Metals

     The only  two metals that were found  in the  raw leachate in
concentrations  greater  than 1,000 jug/1  were  iron and manganese.
Average reductions  of these and other metals  ranged from 0 to 69
percent  (for  iron) .    Only the  effluent concentration of  iron
remained over 1,000 M9/1/ while the average effluent concentrations
of  all  other metals  except manganese,  aluminum,  and  boron were
below 100
Organic Pollutants

     No organic  pollutants were detected in the activated sludge
system effluent;  however,  only two compounds, bis (2-chloroethyl)
ether and thioxanthone, were found in the raw leachate  and at very
low concentrations.

     In  summary,  the  performance   of  biological  systems  for
treatment of  leachate cannot be adequately evaluated due to:  (1)
having data from only  one treatment system employing biological
treatment,  and (2)  the low strength  of  the raw leachate treated
by the system.   Further, employing solely biological treatment is
not a common  practice for leachate.   Section 6.1.5 discusses the
more advanced leachate  treatment  systems.


6.1.4.2  Residuals Data

     Table  6-4 lists the metals that were found to  be concentrated
in the  sludge waste from  the  biological system.   Although lead,
copper, chromium, arsenic,  molybdenum, tin, and cobalt were present
in the raw  leachate  and effluent at  concentrations that averaged
below 100 M9/1/  tne treatment  system  provided  significant removal
of metals as evidenced by their high concentrations in  the sludge.
Aluminum, iron, and manganese, which were among the metals showing
the  highest   percent   reductions,   also were  present  in  high
concentrations in the sludge.   The poor  removal of boron also was
demonstrated  by  a  relatively low   sludge  concentration.    The
toxicity characteristic leaching procedure  (TCLP)  results  showed
that manganese,  zinc, and  boron have  the highest concentration  in
the TCLP  extract.  Two dioxins/furans  also were detected  in the
sludge, but at very low concentrations.


                                99

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 TABLE  6-3.   CONCENTRATIONS  OF POLLUTANTS IN BIOLOGICAL TREATMENT
              SYSTEM EFFLUENT - LEACHATE SUBCATEGORY
                            Effluent Concentration      Mean  %
Pollutant            Units  Minimum   Maximum   Mean    Removal(1)
BOD5
COD
TOC
TSS
Ammonia
TKN
Oil & Grease
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
•» MB
74
66
14
14
15.8
1.9
__
110
69
27
14
17
9.5
39
92
68
20
14
16
5.7
0
0
3
0
17
6
0
Aluminum              M9/1      300      490     395       34
Iron                  Mg/1    3,900    5,400   4,650       69
Manganese             Mg/1      400      590     495       44
Boron                 Mg/1      220      250     235        0
Lead                  Mg/1      <50      <50     <50       (2)
Vanadium              Mg/1       23       36      30        0
Barium                Mg/1       43       49      46       33
Cadmium               Mg/1       <5       <5      <5       (2)
Molybdenum            Mg/1      <10      <10     <10       29
Cobalt                Mg/1        4        7.2     5.6     60
Chromium              Mg/1       49      100      74       29
Copper                Mg/1       37       96      66        0
Nickel                Mg/1       41       45      43        0
Titanium              Mg/1       23       26      24        0
Zinc                  Mg/1       31       43      37        0
Arsenic               Mg/1       15       21      18       33
Antimony              Mg/1      <10      <10     <10       (2)
Mercury               Mg/1        0.6      0.8     0.7      0
Tin                   Mg/1      <13      <13     <13       (2)

Bis(2-Chloro-
 ethyl)  Ether         Mg/1      <10      <10     <10       17
Thioxanthone          Mg/1      <10      <10     <10       80
NOTES :

(1)   Mean % removal  was  calculated using the EPA-ITD sampling data
     from the landfill with biological treatment of leachate.  The
     formula used to calculate the % removal was:

                       n
     Mean % Removal  = V~l (mean influent - mean effluent^ x 100
                      ^ +         mean influent
                       i __   _ _
                                        n
                               100

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TABLE  6-3.   CONCENTRATIONS OF POLLUTANTS IN BIOLOGICAL TREATMENT
        SYSTEM EFFLUENT - LEACHATE SUBCATEGORY (Continued)
NOTES: (Continued)

     Mean  influent  refers  to  the  influent  to  the  biological
     treatment  systems,  mean  effluent  is  the  clarified plant
     effluent.  This sampling data is contained in Appendix A  (Site
     C).

     n =  1,  the number of landfills with biological treatment on
            the EPA-ITD sampling program.

     For  those  pollutants  where  effluent  concentrations  were
     reported   less  than  the  detection  limit   (for   example,
     thUoxanthone,  <10 M9/1), the detection  limit (10 M9/1) was
     us,ed in the  calculation.
       i
 (2)  % removal  has not been reported  for these pollutants since
     both  influent  and  effluent  concentrations  are  below the
     detection  limit.
                                  101

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 TABLE 6-4.
CONCENTRATIONS OF POLLUTANTS IN BIOLOGICAL  TREATMENT
SYSTEM  SLUDGE  -  LEACHATE SUBCATEGORY(1)
Pollutant
Total HpCDF
OCDF
                 Sludge  Sample
            (nig/kg) (2)        (ppt)
Results of TCLP
    (Mg/1)(3)
Aluminum
Iron
Manganese
Boron
Lead
Copper
Chromium
Arsenic
Molybdenum
Tin
Cobalt
Vanadium
Barium
Cadmium
Nickel
Titanium
Zinc
Antimony
Mercury
17,600
206,000
1,520
450
909
3,790
4,150
864
450
460
227
400
450
73
181
350
481
114
3.60
607
623
4,400
1,330
<200
235
88
<20
<100
106
107
<50
598
<10
164
<50
1,660
<20
<0.2
                                0.07
                                0.31
NOTES:

(1)   The biological  treatment  system sampled  was  an  activated
     sludge plant.  The sludge sample was dewatered sludge from the
     activated sludge system.

(2)   mg/kg reported on a wet basis.

(3)   TCLP = toxicity characteristic leaching procedure.
                                 102

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6.1.5  Advanced Treatment
6.1.5.1  Treated Effluent Data

     Two  facilities sampled  during the  EPA-ITD  study  provided
advanced  treatment  for  landfill  leachate.    One  facility  used
biological treatment and clarification  followed by  filtration, air
stripping, and  two-stage carbon adsorption.    Discharge  was  to a
POTW.    The  other  facility  used  aerated  equalization,  lime
precipitation  and  clarification,   ammonia  stripping,  activated
sludge biological  treatment,  clarification,  sand filtration, and
chlorination prior to direct discharge to surface waters.


Conventional and Nonconventional Pollutants

     Table 6-5  summarizes  effluent data for selected pollutants.
The advanced treatment  systems  provided 54  to 78 percent removal
of BOD5,  COD, and  TOC.  Effluent BOD5_ concentrations averaged 8.2
mg/1, typical of advanced wastewater treatment  system performance.
Ammonia  and  TKN  also  showed  significant reductions  (90 to  92
percent), averaging  14 mg/1 in the effluent.


Metals

     Aluminum,  iron, manganese, andQborpii were the  only metals
found  in raw leachate at concentrations  higher  than 1,000 M9/1-
Average  reductions  of  these metals  ranged  from  36 to  over  90
percent;  however,  the effluent concentrations of  boron  and iron
averaged  over 1,000  M9/1-  Effluent concentrations of other toxic
metals  (i.e.,  cadmium,  chromium,  copper,  lead,  nickel,  arsenic,
etc.) were below 100 M9/1-


Organic  Pollutants

     Six  toxic  organic  compounds and one pesticide were detected
in the effluents after  advanced treatment as shown in Table 6-5.
None of  the  organics found in the effluents were detected in the
raw leachate.  Seven different organic  pollutants found in the raw
leachate  were below  their detection limits in  the  effluent.  This
apparent  anomaly may be due to the detention  time of  the treatment
systems.  Consequently,  no conclusions  regarding  the effectiveness
of advanced treatment systems for removal of  toxic  organics can be
made from the limited sampling data.

     In   summary,    the  advanced   treatment   systems   provide
significantly higher reductions of conventional and nonconventional
pollutants  and  metals  as  compared  to preliminary  or  solely
biological treatment systems.   Long-term sampling  is  needed to

                               103

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TABLE 6-5.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED
TREATMENT SYSTEM EFFLUENTS  - LEACHATE SUBCATEGORY(2)

Effluent
Pollutant Minimum
BODS, mg/1
COD, mg/1
TOC, mg/1
TSS, mg/1
Ammonia, mg/1
TKN, mg/1
Oil & Grease, mg/1
Aluminum
Iron
Manganese
Boron
Zinc
Barium
Nickel
Arsenic
Copper
Chromium
Lead
Vanadium
Cadmium
Molybdenum
Tin
Cobalt
Antimony
Titanium
Mercury
Benzidene
B i s ( 2 -chl oroethoxy ) Methane
Dibenzofuran
Dimethyl Phthalate
N-Dodecane (N-C12)
N-Octacosane (N-C28)
TEPP
MCPP
Toluene
Chloro-3-Methylphenol, 4-
Thioxanthone
Acetone
Alpha-Terpineol
Isophorone
N-Tetracosane (N-C24)
Vinyl Acetate
Dibenzothiophene
1
176
52
1582
5.2
9.8
<1
94
310
53
4,700
20
74
<12
6.2
5.6
7
<50
<2
<5
<10
<13
4.5
<10
12
<0.2
<50
<10
<10
<10
<10
<10
1946
<5
<10
<10
<10
<50
<10
<10
<10
<10
<10
Concentration ( 1) Mean %
Maximum
17
464
87
3280
19
19
1.3
220
2,820
1,070
7,100
300
708
88
7.6
16
15
<50
6
<5
<10
<13
15
<10
50
<0.2
198
114
203
39
85
51
223e
<5
<10
<10
<10
<50
<10
<10
<10
<10
92
Mean Remova 1(3)
8
271
72
2289
14
14
1.1
144
1,408
599
5,505
155
473
64
7.1
9.5
11
<50
3
<5
<10
<13
8.3
<10
25
<0.2
87
36
58
17
42
20
208e
<5
<10
<10
<10
<50
<10
<10
<10
<10
30
78
54
63
33
92
90
2
47
92
79
32
0
32
45
47
32
66
(4)
78
(4)
(4)
(4)
55
(4)
30
(4)
0
0
0
0
0
0
39
9
13
8
46
23
19
16
44
13
A. *•*
0
                         104

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      TABLE 6-5.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED
TREATMENT  SYSTEM EFFLUENTS  - LEACHATE SUBCATEGORY(2)  (Continued)
& = estimated value

NOTES:

(1)  All concentrations expressed in M9/1, unless otherwise noted.

(2)  Data presented in this table reflects the two landfills in the
     EPA-ITD sampling data base with  advanced  treatment.   These
     landfills  are   Site  A,  which  has  biological  treatment,
     clarification,   filtration,    air  stripping,   and   carbon
     adsorption;   and  Site   B,   which  has  equalization,   lime
     precipitation and clarification, ammonia stripping, activated
     sludge, clarification, filtration and chlorination.

(3)  Mean % removal was calculated using EPA ITD sampling data from
     landfills  with  advanced  leachate  treatment  systems.    The
     formula used to  calculate the  % removal was:

                        n
     Mean % Removal =  >   (mean influent - mean effluent) x 100
                       L—i           mean influent
                       i	
                                         n
     Where  mean influent  and mean effluent  concentrations were
     calculated for each  landfill with advanced treatment  (Sites
     A and B) using the data in Appendix A.  Influent reflects raw
     leachate  quality  and  effluent  is  final  treatment  plant
     effluent sampled downstream  of all treatment units.

     n = 2,  the number of landfills in the EPA-ITD sampling data
     base with advanced treatment.

     For  those  pollutants  where  effluent   concentrations  were
     reported less than the detection limit  (for example, toluene,
     <10 M9/1) / the detection limit was used in the calculation  (10
(4)  Mean % removal is not reported for those pollutants where both
     influent and effluent concentrations were below the detection
     limit.
                                  105

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evaluate the effectiveness of the advanced systems for removal  of
specific toxic organic pollutants from leachates.


6.1.5.2  Res iduals Data

     Selected metals  and toxic  organics  found in  the advanced
treatment  system sludges are summarized  in Table  6-6.   Iron,
aluminum,  and  manganese,  found  in  the  raw  leachate  in high
concentrations  and  significantly reduced  by  advanced treatment,
also were found  in high concentrations in the sludge.   On the other
hand, chromium and vanadium were not present in high concentrations
in the  raw leachate;  however, the  advanced  treatment system was
highly effective  in removing  these  metals  and concentrating them
in the sludge.  The  TCLP  results  showed that manganese, boron, and
barium  have  the highest  concentrations  in the  TCLP  extract.
Relative  to  its sludge  concentration,  molybdenum  was readily
leached from the sludge in the TCLP test.

     Approximately  50 percent of  the organics detected  in the
sludges were not found in either the raw leachates or the treated
effluent.  Again, this may be partially due to detention times  in
the treatment system in addition to sludge age and sludge wasting
rates.   Only  one sludge sample was analyzed for dioxins/furans.
The isomer, OCDD, was detected at a concentration of 101 ppt.


6.1.6  Other Control and Treatment Technologies

     In  addition to  treatment  and  discharge,  the  HWT industry
manages  leachate  by recirculation,   solidification  and reburial,
deep well  injection,  and contract  hauling to  aqueous hazardous
waste treaters.  Recirculation involves spraying  collected leachate
back  onto open landfill cells  to enhance  evaporation of  the
leachate.  This  practice  is not limited to arid areas  of the  United
States.   Solidification  and  reburial is practiced  when leachate
volumes are relatively small.  Raw leachate is mixed with lime  or
other chemical fixation materials to a consistency that passes the
Resource Conservation  and Recovery  Act  (RCRA)  test  for a solid
(i.e.,  no  free  liquid)  and  reburied in the  landfill.   Deep well
injection  also   is  used  by  facilities with  small volumes   of
leachate.  This  practice  is limited  to areas where injection wells
are common, such as Texas and Louisiana.   Hauling of leachate  to
an aqueous  hazardous  waste  treater is  a  common,  yet expensive
option.  In some cases,  this  practice is used as the last  resort
after a POTW rejects the  leachate; in other cases, landfill  owners
prefer sending  the  leachate  to  a commercial  aqueous treater for
liability reasons.
                               106

-------
          TABLE  6-6.    CONCENTRATIONS  OF  SELECTED  POLLUTANTS  IN
       ADVANCED TREATMENT  SYSTEM SLUDGES  -  LEACHATE  SUBCATEGORY
                                 Sludge Sample
Pollutant
                      Units(2)  Minimum   Maximum   Mean
                                                  Results of TCLP (ug/l)(3)

                                                  Minimum   Maximum   Mean
Aluminum
Iron
Manganese
Boron
Zinc
Barium
Arsenic
Molybdenum
Nickel
Antimony
Vanadium
Titanium
Cadmium
Chromium
Cobalt
Copper
Lead
Tin
Mercury
Acetone
Benzidine
Ethylbenzene
Isophorone
N-Octacosane (N-C28)
N-Eicosane (N-C20)
N-Hexacosane (N-C26)
N-Tetracosane (N-C24)
Toluene
Butanone, 2- (MEK)
Isobutyl Alcohol
Bis(2-Ethylhexyl)
Phthalate
OCDD
NOTES:
(1) Data presented
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Mg/l
Mg/l
M9/1
/ig/l
/tg/l
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1

M9/1
PPt

is from
2,080 4,
1.910 396,
48 35,
113 1,
13 1,
<17 7,
<4
39
6
--
<9
85
20
18
<10
<5
--
<17
--
<50
<50
<10
<10
<10
<22 2,
<22 5,
<10
<10
<50 2,
<10

<22 2,
--

sludge analyses
880
000
600
930
380
880
407
105
102
--
141
200
35
124
64
127
--
84
--
72
252
12
390
81
807
645
--
39
070
12

704
--

of
3,480
199,000
17,800
1,020
696
3,950
206
72
54
<4
75
142
28
71
37
66
225
50
<0.2
61
151
11
200
46
1,415
2,834
<22
24
1,060
11

1,363
101

landfills with
<200
--
<15
666
46
--
<20
--
--
--
<50
<50
<10
--
<50
<25
<200
<100
<0.2
--
--
--
--
--
--
--
--
--
--
--


--

advanced
<200
--
12,500
4,860
730
--
<20
--
--
--
<50
<50
<10
--
<50
<25
<200
<100
<0.2
--
--
--
--
--
--
--
--
--
--
--


--

treatment
<200
250
6,260
2,760
388
4,240
<20
223
57
51
<50
<50
<10
80
<50
<25
<200
<100
<0.2
--

--
--
--
101
142
156
--



<10
--

(Sites A
(2)


(3)
EPA-ITD  sampling data  base.  The Site  A sludge sample (treatment consists  of biological  treatment,
clarification, filtration, air  stripping,  neutralization, and carbon adsorption) was collected from
the bottom of  the  clarifier.    The Site B  sludge sample  (treatment  consists  of  equalization,
flocculation,  clarification,  ammonia stripping, activated  sludge,  filtration and chlorination)  was
taken  from the filter press which dewaters  both clarifier  bottoms and wasted  sludge from the activated
sludge unit.

Metals concentrations  in mg/kg  reported on a wet sludge basis,  organics  in ftg/l,  and dioxins/furans
in ppt,  as indicated.

All TCLP concentrations are in  /tg/l. TCLP  toxicity characteristic  leaching procedure.

Not tested.
                                                   107

-------
6.1.7  Summary

     A wide range of  leachate treatment technologies are employed,
depending  on  the  requirements  of  the receiving  POTW  or NPDES
permit.  In addition to treatment and discharge, the HWT industry
manages  leachate  by  recirculation,  solidification  and reburial,
deep well  injection, and  contract  hauling to  aqueous hazardous
waste treaters.

     Advanced leachate treatment  systems  that involve biological
treatment  and physical/chemical effluent  polishing processes are
capable  of achieving up to  90 percent  removal of BOD5, COD, TOC,
ammonia,  and  TKN.   These  systems  have  achieved  effluent BOD5
concentrations of  10 mg/1  or less.   Even  with advanced treatment
systems, iron and boron effluent concentrations average over 1,000
Mg/1.    Raw  leachate concentrations  of  other  toxic  metals  are
usually  below 500 /ig/1  and frequently less than  100  M9/1-  Some
metals removal occurs during the biological treatment  process, as
evidenced  by  the concentrations of metals in the  sludges.   The
metals with the  highest  concentrations in the  sludges are those
with  high  concentrations  in  the  raw  leachate  (i.e.,  iron,
manganese, aluminum).  Boron,  whose concentrations are frequently
high in  raw leachate,  demonstrates relatively  poor removal with
high   effluent   concentrations   and   relatively   low   sludge
concentrations.

     Several organic compounds were  detected in the effluents from
the  advanced  systems.   With the exception of one pesticide,  the
concentrations averaged less than 100 ^g/1- More organic compounds
were detected in the  sludge from the biological process, including
2-butanone, whose concentration averaged over  1,000 jj.q/1.  Whether
or not difficulties with the analytical methods have any effect on
the organics data for treated leachate cannot be determined because
there are no data from other studies for comparison.


6.2  SCRUBBER WASTEWATER TREATMENT

     Scrubber wastewater  treatment  systems  are  either  chemical
precipitation/sedimentation processes  or  chemical precipitation/
sedimentation with  filtration  and  activated carbon.   Chemical
precipitation/sedimentation systems  are used to treat recirculating
scrubber wastes and  scrubber blowdown.  When regulatory agencies
impose  more  stringent  limits  on  the blowdown  discharge,  the
blowdown portion  of  the  scrubber wastewaters, is  treated  further
with filtration and activated carbon.
6.2.1  Sources of Data

     All data regarding treatment  technologies and effluent data
were   obtained  from the  EPA-ITD study  sampling  and presampling

                               108

-------
efforts.  Telephone contacts supplied information on other scrubber
wastewater management practices.


6.2.2  TSCA versus RCRA Facilities

     Both Toxic  Substances  Control  Act (TSCA)  and permitted RCRA
incineration facilities are  required to control the stack emissions
of  hydrogen  chloride  gases.    This  requires  wet   scrubbers.
Consequently, both TSCA and RCRA  incinerators generate scrubber
wastewater.   The  chloride  content of  PCB-burning TSCA scrubber
wastewaters  is  normally higher because of  the larger amounts of
chlorinated  wastes  burned  compared  to   RCRA  facilities.    No
differences  between TSCA and  RCRA facilities were  found  in the
technologies employed  for scrubber wastewater treatment prior to
discharge.    If  additional  treatment of  the   blowdown  stream
occurred, it was  in response to state or local permit conditions.
For example, a TSCA facility in Region V discharging to a POTW used
filtration and activated carbon to  polish their effluent, while a
TSCA facility in Region VI discharged the blowdown from  a chemical
precipitation/sedimentation  system  directly  to  surface  waters
without  further  treatment.
 6.2.3  Physical/Chemical Treatment

     Two incineration  facilities  sampled during the EPA-ITD study
 provided   only   chemical  precipitation/sedimentation  prior  to
 discharge.    One  facility  was  a  TSCA  incinerator,  and  both
 facilities discharged  directly  to surface waters.


 6.2.3.1  Treated Effluent  Data


 Conventional and Nonconventional  Pollutants

     The precipitation/sedimentation treatment systems provided no
 significant  reduction  of  COD or  TOC;  however,  the TOC  data
 indicated  a  relatively low concentration  of  TOC  in the scrubber
 wastewaters, as shown in Table 6-7.   Only minimal  reduction in TSS
 was  achieved,  but the effluent concentrations averaged 51 mg/1.
 Both  high  TDS  and chloride  concentrations  were present  in the
 effluents as a result of the removal of hydrogen chloride gases by
 the  scrubbers.    Effluent  fluoride  concentrations  averaged 10.3
 mg/1.


 Metals

     Aluminum,  iron, boron, and zinc were  found in  concentrations
 higher than  1,000  ng/l in the  treatment system effluents.  Mean

                                109

-------
   TABLE 6-7.   CONCENTRATIONS OF POLLUTANTS IN PHYSICAL/CHEMICAL
  TREATMENT SYSTEM EFFLUENTS - SCRUBBER WASTEWATER SUBCATEGORY(1)
Pollutant
COD
TOC
TSS
TDS
Chloride
Fluoride
Ammonia
TKN
Calcium
Magnesium
Aluminum
Iron
Zinc
Boron
Copper
Manganese
Tin
Lead
Barium
Cadmium
Molybdenum
Vanadium
Cobalt
Chromium
Nickel
Titanium
Arsenic
Antimony
Mercury
Acetone
Benzene
Benzo(b) fluoranthene
Thioxanthone
Bromoform

Effluent
Concentration
Units Minimum Maximum
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Mg/1
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
129
14
32
4,060
2,300
0.65
<0.1
1.3
490
4.8
780
383
200
220
34
118
<13
72
180
6
130
2
<4
13
58
11
5
28
0.2
<50
<10
<10
<10
<10
840
60
100
11,100
9,000
15
<0.1
5.9
3,790
390
1,130
1,900
1,490
1,550
794
400
<13
383
485
25
360
17
6.2
21
81
67
37
58
0.4
90
59
12
366
38
Mean %
Mean Removal ( 2 )
423
45
51
7,820
5,550
10.3
<0.1
3.2
2,110
182
1,020
1,030
676
710
288
240
<13
180
280
16
195
9
4.8
16
69
38
21
39
0.3
60
22
10
99
17
0
10
13
0
2
38
(3)
14
0
4
78
76
43
18
61
26
92
50
10
25
13
43
40
81
56
74
27
10
44
6
2
0
0
0
Heptachlor Epoxide    Mg/1

-------
  TABLE 6-7.  CONCENTRATIONS OF POLLUTANTS IN PHYSICAL/CHEMICAL
 TREATMENT SYSTEM EFFLUENTS - SCRUBBER WASTEWATER SUBCATEGORY(1)
                            (Continued)
NOTES:

(1)  Data presented are the results of the EPA-ITD sampling program
     of the Scrubber subcategory with physical/chemical treatment
     systems (Sites H and J).

(2)  Mean % removal was calculated using the EPA-ITD sampling data
     for the two scrubbers with physical/chemical treatment  (Sites
     H and J) using the following formula:

                       n

     Mean % Removal =  \  (mean influent  - mean  effluent) x 100
                       / .1              mean influent
                                             n

     Where  mean influent  and mean effluent  concentrations were
     calculated for each of the scrubbers (Sites H and J) using the
     data in Appendix B.  Influent refers to raw scrubber wastewater
     and effluent to the facilities final, treated wastewater.

     n = 2,  the number  of  scrubbers with physical/ chemical
     treatment in the EPA-ITD sampling data base.

     For  those  pollutants  where  effluent   concentrations  were
     reported less than the detection  limit (for example, tin, <13
     Mg/1)  the  detection   limit   (13  Mg/1)  was  used  in  the
     calculation.

(3)  Mean  % removal  is not  reported for pollutants  where both
     influent and effluent concentrations were below the detection
     limit.
                                  Ill

-------
reductions of these metals ranged from 18 to 78 percent, with boron
showing  the   lowest  average  percent  removal   and aluminum  the
highest.   Arsenic, cadmium, lead, tin, titanium, nickel, chromium,
antimony, and vanadium were found at effluent concentrations below
100 /ig/1-  The treatment systems provided significant removals of
some of these metals.
Organic Pollutants

     Five toxic organic pollutants and one pesticide were detected
in the treated effluent, but at relatively low concentrations.  The
presence of only a few organics at low concentrations is expected
in scrubber wastewaters from properly operated incinerators.  The
organics present may have been contaminants in the surface and well
waters that supply the scrubbers with make-up water.

6.2.3.2  Residuals Data

     Selected metals,  toxic organics, and dioxins/furans found in
the physical/chemical treatment  system  sludges  are summarized in
Table  6-8.   Thirteen metals  were  found at  concentrations above
1,000  mg/kg  in the  sludges,  including metals whose  effluent
concentrations  were  below  100  Mg/1  (i-®-/  lead,  tin,  nickel,
titanium, chromium, and vanadium) .  Copper, which averaged 288 p.q/1
in the effluent, was highly  concentrated in the sludges.  The TCLP
extracts showed  little  leaching  potential for  most metals except
boron, zinc, and barium.

     Two toxic  organics, acetone and bromoform,  were detected in
the sludges.  The concentration  of  acetone  was  relatively high.
Although  not  detected  in  the  compositional  analysis,  three
additional  organics  were  found  in the  TLCP  extracts,   but  at
relatively low concentrations.

     The most  significant finding in the sludge analyses was the
presence of a  large number  of  dioxin/furan  isomers,  some at high
concentrations.   Neither the  raw  scrubber  wastewaters  nor  the
treated  effluents were tested  for  these  pollutants,   so  the
effectiveness of physical/chemical treatment systems in the removal
of dioxins/furans is unknown.   The presence of at least 10  isomers
in the sludges at  concentrations in the ppb range indicates the
need for  more extensive analyses,  including analyses of the treated
effluents for dioxins/furans.


6.2.4  Advanced Treatment

     Only  one   incineration  facility  sampled  provided  advanced
treatment  of  their scrubber  wastewater prior  to discharge.   A
second facility, which was  visited but not sampled, also provided
advanced treatment.    Both  advanced  treatment  systems  followed

                               112

-------
   TABLE 6-8.    CONCENTRATIONS  OF POLLUTANTS  IN  PHYSICAL/CHEMICAL
   TREATMENT  SYSTEM  SLUDGES -  SCRUBBER  WASTEWATER SUBCATEGORY(1)
                               Sludge Sample
Pollutant
             Units(2)  Minimum  Maximum   Mean
Results of TCLP (ug/l)(3)

Minimum  Maximum   Mean
Aluminum
Iron
Manganese
Boron
Zinc
Lead
Tin
Copper
Titanium
Nickel
Chromium
Barium
Vanadium
Antimony
Arsenic
Cadmi urn
Cobalt
Molybdenum
Mercury
Acetone
Bromoform
Chloroform
Methylene Chloride
Isobutyl Alcohol
1,2,3,4,6,7,8-HpCDD
Total HpCDD
OCDD
1,2, 3, 7,8-PCDF
2,3,4, 7,8-PCDF
Total PCDF
1,2,3,4,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,6,7,8-HxCDF
Total HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
Total HpCDF
OCDF
2,3,7,8-TCDF
NOTES:
(1) Data presented
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
M9/ 1
M9/ 1
M9/ I
M9/ 1
M9/ 1>
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt

are based
20,600
11,500
575
4,740
732
239
217
116
359
86
64
92
22
--
--
19
--
96
--
<50
<10
--
--
--
<3.79
<3.79
4.69
42.8
84.6
117
22.6
155
<0.95
187
88.2
<3.38
261
559
61.2

on sludge
289,000
228,000
14,200
7,990
97,800
74,200
21,200
92,500
9,890
18,200
5,530
3,370
2,260
--
--
978
--
1,300
--
1,496
32
--
--
--
31
67
155
838
4,296
16,000
1,596
1,178
353
6,966
773
59
1,354
2,966
3,785

analyses
154,800
120,000
7,390
6,360
49,300
37,200
10,700
46,300
5,120
9,140
2,800
1,730
1,140
21
25
499
345
698
0.88
773
21
<10
<10
<10
.1 17.5
.0 35.4
79.7
441
2,177
8,058
809
666
177
3,576
431
.8 31.6
808
1,762
1,923

from the two
659 852
<100 108
182 189
1,510 2,180
1,400
--
169 193
26 127
--
<40 67
--
1,270 1,420
--
--
--
<10 54
--
226 491
<0.2 0.2
-.
--
--
--

















incinerator scrubbers
756
104
186
1,840
--
275
181
76
<50
54
<50
1,340
<50
21
<20
32
<50
358
0.2
145
30
15
80
11
















with phys-
       treatment in the EPA-ITD sampling data base.  The scrubber  wastewater treatment  systems  at both  of
       these facilities (Sites H and I) consists of neutralization, clarification and cooling lagoons. Sludge
       samples were taken  from the clarifiers.

(2)    Metals concentrations in mg/kg (wet basis), organics in /ig/l, TCLP in ng/\. and dioxins/furans in ppt.
(3)
TCLP = toxicity characteristic leaching procedure.
                                                113

-------
chemical precipitation/sedimentation  with filtration  and  carbon
adsorption.


6.2.4.1  Treated Effluent Data

Conventional and Nonconventional Pollutants

     TSS reduction  averaged  over  99  percent and  TOG reduction
averaged 89  percent  by the advanced treatment  system.  However,
the  percent  reductions  are  misleading  because  this  facility
recirculated its scrubber water with  a high  TSS load and treated
only the blowdown  stream.  Effluent TSS and TOC concentrations
averaged  88  and 45  mg/1,  respectively  (Table  6-9)  which is
comparable to physical/chemical  system effluents (Table 6-7).  The
effluent fluoride  concentrations  were  also  similar for  the two
types  of  treatment  systems.    Because  the  sampled  facility
recirculated high TSS concentrations in its scrubber water and  only
treated the  blowdown,  ammonia was added to the scrubber water to
neutralize  the acid  gases.    As a  result  of  this  operational
procedure,  high ammonia and TKN concentrations  were found  in the
treated effluent.   Although the treatment  system  achieved a 50
percent reduction  in  the ammonia,  its  effluent  concentrations
averaged 1,070 mg/1.


Metals

     Sixteen metals were  found  in the  raw scrubber wastewater at
concentrations  higher  than  1,000  M9/l«   Recirculation  of  the
scrubber water  and treatment  of only the blowdown stream is the
reason  for the high  metals  concentrations  compared to  the raw
scrubber water  discussed  in Section  6.2.3.    Of these  16 metals,
aluminum,   lead, chromium, copper, iron,  titanium,  zinc,  tin, and
arsenic had  removals of 99  percent or  greater  with the advanced
treatment system. Greater than  99 percent removal  of mercury  also
was achieved with  an effluent  concentration of <0.2  /ig/1.   The
percent removals  of vanadium,  barium,  molybdenum, cobalt,  and
antimony were  90 percent or  greater.    Even with  high  percent
removals,  the effluent  concentrations  of  iron,  manganese, boron,
and  zinc   were  above  1,000  M9/1;   however,   the  effluent
concentrations of aluminum, lead, tin,  cobalt, chromium, titanium,
and arsenic averaged below 100 p.g/1.


Organic Pollutants

     Six toxic  organic pollutants were detected  in  the treated
effluent after  carbon adsorption.  Only thioxanthone also was found
in the  raw scrubber wastewater.   Three  other  organic compounds
found in the raw scrubber water were  treated to below detection
level concentrations.

                               114

-------
TABLE 6-9.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED TREATMENT
        SYSTEM EFFLUENTS - SCRUBBER WASTEWATER SUBCATEGORY
Pollutant
COD, mg/1
TOG, mg/1
TSS, mg/1
TDS, mg/1
Chloride, mg/1
Fluoride, mg/1
Ammonia-N(4) , mg/1
TKN(4) , mg/1
Calcium, mg/1
Magnesium, mg/1
Iron
Manganese
Boron
Molybdenum
Nickel
Zinc
Antimony
Aluminum
Lead
Vanadium
Barium
Cadmium
Tin
Cobalt
Chromium
Copper
Titanium
Arsenic
Mercury
Butyl Benzyl Phthalate
N-Dodecane (N-C12)
N-Tetradecane (N-C14)
Chloronaphthalene, 2-
Chlorophenol , 2-
Thioxanthone
Fluoranthene
N-Nitrosodi-N-Propylamine
Pyrene
Effluent
Minimum
310
16
17
9,700
—
12
820
80
180
100
1,100
1,600
7,100
650
470
570
340
13
<50
<2
190
170
—
71
5
88
<10
6
<0.2
<10
<10
<10
<10
<10
<10
<10
<20
<10
Concentrati
Maximum
380
74
160
9,800
—
15
1,320
270
410
130
1,100
1,800
12,000
1,200
600
3,000
545
45
<50
<2
210
210
--
86
15
130
<10
11
<0.2
15
28
15
48
10
392
<10
<20
<10
on(l)
Mean
345
45
88
9,750
4,000
14
1,070
175
295
115
1,100
1,700
9,550
925
535
1,780
442
29
<50
<2
200
190
<65
78
10
109
<10
8
<0
13
19
13
29
10
201
<10
<20
<10
Mean %
Removal (3)
25
89
99
0
0
94
51
0
75
79
99
82
28
91
89
99
90
99
99
98
97
89
99
91
99
99
99
99
.2 99
0
0
0
0
0
90
83
98
94
                                115

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TABLE 6-9.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED TREATMENT SYSTEM
       EFFLUENTS - SCRUBBER WASTEWATER SUBCATEGORY (Continued)
  NOTES:

  (1)  All concentrations expressed  in ng/1, unless otherwise noted.

  (2)  Data presented are the  results of the EPA-ITD sampling effort
       at incinerators with advanced scrubber wastewater treatment
       systems  (Site  G) .   Site G treatment  includes flocculation,
       clarification, filtration,  and carbon adsorption.

  (3)  Mean % removal was calculated from EPA-ITD sampling data for
       the   incinerator   with  advanced   treatment   of  scrubber
       wastewaters using the following formula:

                          n

       Mean % Removal =  X'  (mean  influent  - mean effluent)  x 100
                         L.	^             mean influent
                          i	
                                             n

       Where mean  influent and mean  effluent concentrations  were
       obtained from Sites G sampling data contained in Appendix B.
       Influent samples  were  raw  scrubber wastewater  and effluent
       samples were final treated effluent from the carbon adsorption
       units.

       n  = 1, the number of incinerators  in the EPA-ITD sampling data
              base with advanced treatment.

       For  those   pollutants  where  effluent  concentrations  were
       reported less than the  detection limit  (for example, lead <50
       Mg/1),  the  detection   limit  (50  Mg/1)  was  used  in  the
       calculation.

  (4)  Data reported are  the unedited laboratory analytical results.
       Analytical  problems are evident here where ammonia  is reported
       higher  than TKN.  Possible  explanations  are  discussed  in
       Section 5.1.
                                   116

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     In  summary,   the  advanced  treatment  system provided  high
removals  of  many  toxic  metals.   Compared  to physical/chemical
treatment, the  advanced  treatment system  achieved significantly
lower  effluent concentrations of aluminum  and  copper.  In general
though, operation of the  scrubber water system  with a low TSS load
(i.e.,   treating   the   recirculating  stream    with   chemical
precipitation/ sedimentation)  produced lower metals concentrations
in the final effluent. Addition of ammonia for neutralization in
the high  TSS mode of operation may affect metals removal due to
formation  of  chemical complexes that  can lower  metals  removal
efficiencies.
6.2.4.2  Residuals Data

     Table 6-10 summarizes concentrations of selected metals, toxic
organics,  and  dioxins/furans  in  the sludge  from the  advanced
treatment system. Although the advanced system includes additional
unit  processes,  sludge   is  only  generated  by  the  chemical
precipitation process.  Eight metals were found at concentrations
above 1,000 mg/kg in  the  sludge,  including metals whose effluent
concentrations were below 100 jug/1 (i.e.,  aluminum, titanium, and
lead).  Zinc,  whose  concentration  ranged  over 1,000  ng/I  in the
treatment system effluent, was highly concentrated in the sludge.
Zinc and  aluminum also were found at  high  concentrations  in the
TCLP extract.   These results  are in direct contrast to  the zinc and
aluminum results for the  sludges from the other physical/chemical
treatment  system and  also  may  be  the  consequence  of  ammonia
addition.  Ammonia forms complexes with metals, which hinder their
removal by precipitation.   These complexes may release metals more
readily than sludges without ammonia.

     Only  one  toxic organic,  thioxanthone,  was  detected  in the
advanced  treatment  system  sludge.   Like  the physical/chemical
system  sludges,  the advanced treatment system sludge  contained a
large  number   of dioxin/furan  isomers  at high  concentrations.
Neither the raw scrubber  wastewater nor the treated effluent were
tested  for dioxins/furans,  but  their  presence  in  the  sludge
indicates  their presence in  the raw  wastewater  and  potential
presence in the treated effluent.


6.2.5  Other Treatment and Disposal Methods

     Treatment  and discharge,  either directly or indirectly, are
the primary management practices  for  incinerators with scrubber
wastewater.     Other  means  of  disposal   include   landfills,
evaporation, and contract hauling.   These methods are applicable
primarily   to   systems   with  small-volume   discharges.   Those
incinerators using contract  hauling  send scrubber wastewaters to
commercial aqueous hazardous  waste treaters.  Prior to  landfilling,
scrubber wastewaters are solidified or chemically fixed.  Lime and

                               117

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   TABLE  6-10.  CONCENTRATIONS OF POLLUTANTS  IN  ADVANCED
TREATMENT SYSTEM SLUDGE - SCRUBBER WASTEWATER SUBCATEGORY(1)
Pollutant
Aluminum
Iron
Lead
Barium
Molybdenum
Copper
Titanium
Zinc
Manganese
Nickel
Boron
Cadmium
Antimony
Arsenic
Chromium
Cobalt
Tin
Mercury
2,3,7,8-TCDF
2,3,7,8-TCCDD
1,2,3,7,8-PCDF
2,3,4,7,8-PCDF
Total PCDF
1,2,3,7,8-PCDD
Total PCDD
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
Total HxCDF
1,2,3,6,7,8-HxCDD
Total HxCDD
1,2,3,4,6,7, 8-HpCDF
1,2, 3,4,7,8, 9-HpCDF
Total HpCDF
1,2,3,4,6,7,8-HpCDD
Total HpCDD
OCDF
OCDD
Units(2)
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
PPt
ppt
ppt
ppt
ppt
ppt
ppt
Sludge Sample
20,300
170,000
14,300
1,460
1,770
2,910
2,140
65,600
818
569
661
184
<145
13
486
121
792
17.6
27.78
16.86
20.15
249.85
694.28
14.69
223.59
117.08
69.88
687.99
26.24
351.35
310.74
49.95
581.53
133.92
297.78
3,722.38
2,209.40
Results of
TCLP(3) (Mg/1)
51,200
399
3,230
1,100
290
9,660
<50
642,000
11,300
2,110
4,790
1,730
325
48
49
626
1,040
<0.2
—
—
—
—
—
—
—
— -
—
—
—
—
— —
—
—
— —
—
— —
—
                             118

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      TABLE 6-10.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED
  TREATMENT  SYSTEM SLUDGE - SCRUBBER WASTEWATER SUBCATEGORY(1)
                            (Continued)
NOTES:

(1)  Data  presented are  the results  of  analyses of  the sludge
     sampled  obtained from  the one  incinerator in  the EPA-ITD
     sampling data base with advanced scrubber wastewater treatment
     (Site G).  Treatment at this facility included flocculation,
     clarification,  filtration, and  carbon  adsorption.  Settled
     solids were sent from the clarifier to a vacuum sludge filter.
     The sludge sampled was collected from the vacuum sludge filter
     discharge.


(2)  Metals concentrations in mg/kg, wet bases.

(3)  TCLP = toxicity characteristic leaching  procedure.
                                  119

-------
sometimes ash  from the  incinerator are  used for  this purpose.
Evaporation in surface impoundments is an option in arid climates
or  in  areas  where land  is inexpensive  and  readily available.
Finally, on-site generators  such as industrial facilities may treat
the  scrubber wastewaters   along  with  their  process wastes  or
comingle the  scrubber  wastewaters with noncontact  cooling water
for discharge.


6.2.6  Summary of Scrubber Wastewater Treatment

     Scrubber wastewater treatment systems consist of technologies
designed  for the  removal  of  inorganic  pollutants.    Chemical
precipitation/sedimentation provides metals removal,  and filtration
and carbon adsorption are used if necessary to polish the effluents
to meet permit limits.   Consequently, no significant reduction in
COD  occurred,  but effluent concentrations  were  relatively low.
Even with  advanced treatment,  effluent concentrations  of iron,
manganese,  boron,  molybdenum,   and zinc were above  1,000 p.g/1.
Effluent concentrations of the toxic metals were below 100
     The most significant result was the presence of a large number
of dioxin/furan isomers, some at extremely high concentrations, in
the scrubber wastewater treatment system sludges.  Dioxins/furans
are  relatively  insoluble   in  water   and  tend  to  adsorb  onto
particulates .   Although the treatment system effluents were not
analyzed for dioxins/furans, these compounds may be discharged to
POTWs or  surface waters by way  of the  suspended  solids  in the
treated effluents.  Further analysis of treated effluents is needed
to determine if  the treatment technologies in-place  are effectively
removing dioxins/furans.    Other  methods of scrubber  wastewater
disposal,  besides the most  common treatment and disposal methods,
include landfills,  evaporation, and contract hauling.


6 . 3  AQUEOUS HAZARDOUS WASTE TREATMENT

     Aqueous hazardous waste treatment systems range from chemical
precipitation/sedimentation  units  designed  to  treat  inorganic
industrial  wastes   to advanced  treatment  systems   that  may
incorporate biological treatment and tertiary treatment in addition
to  chemical precipitation.    Complex facilities  accept  a  wide
variety of wastes for treatment, including leachates and inorganic
wastes.   Treatment operations  may  be  batch treatment,  continuous
flow,  or  both.   Some  facilities  segregate  incoming wastes that
require specialized  pretreatment  (e.g.,  cyanide wastes, chromium
wastes), while  other facilities  use  one waste  to treat another
(e.g.,   mixing  acid  wastes   with  caustic wastes.  Some  facilities
combine all of the  wastes prior to any treatment.
                               120

-------
6.3.1  Sources of Data

     The  two sources  of data  available to  this study  are the
EPA-ITD sampling effort  at  four aqueous hazardous waste treaters
and an Office of Solid Waste (OSW)  sampling program at two other
facilities.  The  EPA-ITD study produced  two  consecutive days of
data (24-hour composites),  while  one of the OSW study facilities
was  sampled for  three  consecutive  days.   Twelve  batches  were
sampled over a 4-day period at the second OSW sampling facility-

     The  list of analytes for the two studies also differed.  At
one OSW sampling facility, the analytes were 15 metals, 29 volatile
organics, TCLP,  and miscellaneous conventional and nonconventional
pollutants.  At the other OSW sampling facility,  the analytes were
35 volatile organics,  58 extractables,  seven metals,  TCLP,  and
miscellaneous conventional  and nonconventional  pollutants.   The
list of  analytes  for  the EPA-ITD study  included  27  metals,  the
Appendix IX organics, pesticides/herbicides, dioxins/furans, TCLP,
and miscellaneous conventional and nonconventional pollutants.
6.3.2  Physical/Chemical Treatment

     Three aqueous hazardous waste treaters operated pretreatment,
chemical precipitation, and solids removal technologies. The first
facility pretreated  oily wastes  prior to mixing with all other
incoming wastes.  The combined wastes were treated by a potential
four-stage chemical precipitation reactor, flocculating clarifier,
and settling  tank.   The second  facility  used batch pretreatment
(only   if   necessary),  oil-water-solids   separation,  chemical
precipitation,  flotation,  and coagulation.   The  third facility
employed   cyanide  oxidation   and  chromium   reduction,   using
iron-bearing  wastes  in the chromium  reduction  process.    The
pretreated wastes were combined  with other wastes  for chemical
precipitation followed by vacuum  filtration for solids removal.
6.3.2.1  Treated Effluent Data
Conventional and Nonconventional Pollutants

     Average  effluent  concentrations  and  percent  removals  of
conventional and nonconventional pollutants are summarized in Table
6-11.  Relatively poor  EOD5,  TOG,  and COD removals were achieved
by treatment technologies designed primarily for the  treatment of
inorganic wastes.  The high effluent BOD.5 and TOC  concentrations
indicate that although the treatment systems are not designed for
removal of organic wastes,  the wastes accepted  at these facilities
contain a significant amount  of organics.   The treatment systems
provided significant TSS reductions  (average 92 percent removal).

                                121

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TABLE 6-11.  CONCENTRATIONS OF POLLUTANTS IN  PHYSICAL/CHEMICAL
     TREATMENT  SYSTEMS  -  AQUEOUS TREATERS SUBCATEGORY(2)
Effluent Concentration (I)
Pollutant
BOD5, mg/1
COD, mg/1
TOC. mg/1
TSS, mg/1
O&G, mg/1
Ammonia(4), mg/1
TKN(4) , mg/1
Phenols, mg/1
Cyanide, mg/1
Fluoride, mg/1
Aluminum
Iron
Boron
Nickel
Zinc
Manganese
Barium
Molybdenum
Antimony
Cadmium
Chromium
Mercury
Copper
Lead
Titanium
Acetone
Alpha-Terpineol
Benzene
Benzidine
Bis (2-Ethylhexyl)
Phthalate
Ethylbenzene
Methylene Chloride
N-Decane (N-C10)
N-Dodecane (N-C12)
Toluene
Trichloroethene
Trichloroethane ,
1,1,1-
Butanone, 2- (MEK)
Chloro-3-
Methyphenol, 4-
Benzyl Alcohol
Bichenvl
Minimum
189
3,360
13
2
34
10.8
60
0.62
0.24
0.6
31,800
4,760
16,000
169
60
42
25
<100
31
<5
100
<.2
32
<10
<10
<50
<10
<10
<50

<10
<10
<10
<10
<10
<10
<10
Maximum
930
11,400
17,000
458
153
870
694
27.5
1.9
370
45,000
21,000
53,000
1,500
6,200
760
120
890
158
20
566
<.4
177
110
11
7,706
5,223
15,407
22,723

4,266
459
360
1,717
20,263
34,931
103
<10 759
<50 108,526
2,205
<10
<10
2,443
2,669
<10
Mean
514
7,180
2,070
79
71
436
223
12.3
1.1
185
36,600
10,050
34,400
456
905
343
61
687
82
10
223
<0. 3
136
23
11
3,760
1,748
3,884
7, 608

1,429
65
46
676
6,761
2,664
16
113
30,030
2,324
675
<10
Mean % Removal (3)
46
34
30
92
88
0
8
18
44
38
6
86
6
53
93
90
64
\J Tt
Of)
& \j
00
O £t
fta
o o
Q-J
O 
-------
TABLE  6-11.   CONCENTRATIONS OF POLLUTANTS IN PHYSICAL/CHEMICAL
TREATMENT SYSTEMS - AQUEOUS TREATERS SUBCATEGORY(2)  (Continued)
Effluent
Pollutant Minimum
Hexanoic Acid <10
Isobutyl Acid <10
Thioxanthone <10
Tripropyleneglycol
Methyl Ether <10
Vinyl Acetate <10
Isophorone <10
Methacrylonitrile <10
Naphtha 1 ene 39
Styrene <10
Dichloroethane, 1,1- <10
Dichloroethane, 1,2- <10
Dibromoethane ,
1,2- (EDB) <10
Diethyl Ether <50
Di-N-Butyl Phthalate <10
N-Docosane (N-C22) <10
Chloronaphthalene, 2- <10
Methylnaphthalene, 2- <10
N-Hexadecane (N-C16) <10
Hexanone, 2- <10
Dinitrotoluene, 2,4- <10
Diphenylhydraz ine
1,2- <20
Pentachlorophenol <50
Methyl Methacrylate <10
Fluorene <10
Tetrachloroethene <10
Chloroform <10
Trans , 1 , 2-Dichloro-
ethene <10
Trichloroethane ,
1,1,2- <10
P-Cresol <10
N-Nitrosomorpholine <10
Butyl Benzyl
Phthalate <10
Phenol <10
Nitrophenol, 2- 655
Benzoic Acid <50
N-Nitrosodi-N-
Butylamine <10
Concentration
(1)
Maximum Mean Mean '
85
82
35,060 8,

5,544 1,
1,230
354
30
162
917
23
37

24
98
520
<10
<10
<10
<10
<10
<10

<20
<50
<10
<10
<10
<10

<10

<10
393
162

<10
4,592 1,
1,693 1,
518

<10
48
28
772

394
315
181
15
119
308
11
12

14
62
180
<10
<10
<10
<10
<10
<10

<20
<50
<10
<10
<10
<10

<10

<10
202
48

<10
561
174
284

<10
fe Removal (3)
32
29
0

0
0
42
0
22
31
29
0

0
0
26
40
46
50
50
48
45

6
28
4
16
21
16

3

8
0
0

44
56
0
0

45
                               123

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 TABLE  6-11.  CONCENTRATIONS OF  POLLUTANTS  IN PHYSICAL/CHEMICAL
 TREATHENT SYSTEMS - AQUEOUS THEATERS SUBCATEGORY(1)  (Continued)
NOTES:

(1)  All concentrations expressed in tig/I, unless otherwise noted.

(2)  Information in this  table  is based on  the sampling results
     from   three   aqueous   hazardous   waste   treaters   with
     physical/chemical treatment  systems:  Site J and  L from the
     EPA-ITD sampling  effort  and one  site from the OSW sampling
     program.   All raw data  from these  sampling  programs are
     contained in Appendix C.

(3)  Mean %  removal  was calculated based  on  sampling data from
     aqueous treaters  with physical/chemical  treatment systems
     using the following formula:
                         n

     Mean % Removal =   \   (mean  influent  -  mean effluent) x 100
                                  mean influent
                                             n
     Where mean  influent is  the raw  waste water  concentration
     calculated individually for each site.   Mean effluent is the
     final treated site effluent.

     n = 3,  the number of aqueous hazardous  waste treaters in the
            data base with physical/chemical treatment.

     For  those  pollutants  where  effluent  concentrations  were
     reported less than the detection limit (for example, biphenyl,
     <10 Mg/1) ,  the  detection  limit  (10 p.q/1)  was used  in the
     calculation.

(4)   Data presented are the unedited  laboratory analytical results.
     Evidence of  analytical problems can be seen here where ammonia
     is  reported higher  than TKN.    Possible  explanations are
     discussed in Section 5.1.
                                 124

-------
The effluent TSS concentration averaged 79 mg/1, which is adequate
for facilities discharging to a POTW.  High effluent oil  and grease
concentrations were found as a result of  the oily wastes accepted
at   aqueous   hazardous    waste   treaters.       The   chemical
precipitation/sedimentation  systems  provided  little reduction of
ammonia, TKN, and phenol,  which is typical of this technology-  It
is  concluded, therefore,  that  these  facilities   accept  wastes
containing high concentrations of conventional and nonconventional
pollutants that are not treatable by the  technologies in-place.


Metals

     Aluminum,  iron,  boron,  nickel,   and  zinc  were  found  in
concentrations higher than  1,000  pq/l in the  treated effluent.
Average reductions of these metals ranged from 6 percent for boron
to 93 percent for zinc.   High percent removals  were observed for
several heavy metals, including cadmium, copper, and  lead.   The
effluent,, concentrations of these metals  were low as  a result of
low concentrations in the raw waste and a high degree of reduction
in the treatment  system.


Organic Pollutants

     Sixteen toxic organic compounds were detected in the treatment
effluent  at  concentrations   above  1,000  M9/1-    Because  the
physical/chemical treatment technologies in-place are not designed
for  organics  removal,  the  average percent  removals  were  low,
ranging from  0 to 75  percent.   The highest percent removals were
achieved for volatile compounds (acetone, ethylbenzene, 2-butanone) ,
which suggests that volatilization may have been one of the removal
mechanisms.

     Fifteen  compounds averaged  zero percent reduction.  Included
among these  were  compounds  with raw  waste  concentrations below
detection limits  but with higher effluent  concentrations.   Such
instances may be attributed to  the detention times in the treatment
systems as well as the analytical difficulties discussed in Section
5.  These factors make it difficult to estimate with accuracy the
removals of these  and other compounds.
6.3.2.2  Residuals Data

     Table   6-12   lists  the   metals,   toxic   organics,   and
dioxins/furans that were found to be concentrated  in the chemical
sludges from the physical/chemical  treatment systems.   Aluminum,
iron, nickel,  chromium,  zinc, and lead were found at concentrations
above 1,000 mg/kg in the sludges.  Aluminum, iron,  boron, and zinc
were found at high concentrations in the TCLP extracts; however,
the TCLP data are from a single sludge  sample.  Twenty-eight toxic

                               125

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TABLE 6-12.  CONCENTRATIONS OF POLLUTANTS  IN  PHYSICAL/CHEMICAL
  TREATMENT SYSTEM SLUDGES - AQUEOUS TREATERS SUBCATEGORY(1)
Sludge Sample
Pollutant
Aluminum
Iron
Nickel
Chromium (total)
Boron
Zinc
Lead
Copper
Manganese
Barium
Molybdenum
Antimony
Cadmium
Yttrium
Mercury
Titanium
Silver
Arsenic
Beryllium
Calcium
Cobalt
Magnesium
Sodium
Selenium
Tin
Titanium
Vanadium
Acetone
Alpha-Terpineol
Benzene
Chlorobenzene
Chloroform
Di-N-Butyl Phthalate
Ethylbenzene
Fluorene
Methylene Chloride
N-Docosane (N-C22)
N-Hexadecane (N-C16)
N-Octadecane (N-C18)
N-Triacontane (N-C30)
N-Nitrosodiphenylamine
Naphthalene
Trans- 1 ,2-Dichloroethene
Trichloroethene
Chloronaphthalene, 2-
Oichlorophenol, 2,4-
Oinitrotoluene, 2,4-
Chloro-3-Methylphenol, 4
Methylnaphthalene, 2-
Isophorone
Units(2)
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
rrg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
M9/1
M9/1
M9/1
M9/1
M9/I
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
M9/1
- M9/1
M9/1
M9/1
Minimum
1,690
2,450
274
344
54
443
63
158
19
33
18
18
10
<8
<0.2
<13
0.30
27
<1
2,040
12
303
1,290
<0.8
34
<1.6
12
<50
--
<2.8
<5.1
<2.8
.-
<3.2
<7.1
..
-.
..
-.
-.
165
<2.8
<2.8
..
..
--
.-
Maximum
15,100
21,300
2,564
6,509
362
1,890
2,680
478
313
1,300
24
30
66
84
101
472
12
45
2.0
61,100
22
2,650
14,200
5.0
47
5.0
27
8,411

289
12
9.9

470
304


__
	
	
13,811
8.9
540


--

Results
Mean Minimum
8,395
11,875
1,532
2,404
208
974
1,089
336
166
455
21
24
35
46
51
243
6.15
36.0
1.5
31,570
17
1,476
7,745
2.9
40
3.3
19
1 , 033
19,260
38 105
6.0
5.3
12,436
116
1,835
41
10,107
9,236
1 2 , 908
13,100
3,675
6,988
4.9
63
21 616
- — .fin
<1U
1 LLn
1 , HHU
4~,477 <10
20 835
tu i ojj ~ -
of TCLP Oig/l)
Maximum Mean
126,000
786,000
1,010
1,249
38,600
26,600
896
<25
871
423
337
<200
33
149
<0.2
<50
20
200
5
340,000
60
46,700
-- 2,540,000
20
100
?n
£U
50
12 Afi1
1 f- i HO 1
<10
333 219
1Pfl
1 C.\J
J*
C.O
180

-------
      TABLE  6-12.    CONCENTRATIONS OF  POLLUTANTS  IN  PHYSICAL/CHEMICAL
TREATMENT  SYSTEM  SLUDGES - AQUEOUS  TREATERS  SUBCATEGORY(1)   (Continued)
    Pollutant
                                       Sludge Sample
                                               Results of TCLP (ng/l)
              Units(2)  Minimum    Maximum   Mean  Minimum  Maximum    Mean
P-Cymene
Styrene
Tetrachloroethene
Toluene
Trichloroethane, 1,1,1-
Butanone, 2- (MEK)
Hexanone, 2-
Dichloroethane, 1,1-
Carbon Disul^ide
Xylenes (total)
1,2,3,7,8-PCDF
2,3,4,7,8-PCDF
Total PCDF
1,2,3,7,8-PCDD
Total PCDD
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
Total HxCDF
1,2,3,6,7,8-HxCOD
1,2,3,7,8,9-HxCDD
Total HxCDD
1,2,3,4,6,7,8-HpCDF
Total HpCDF
1,2,3,4,6,7,8-HpCDD
Total HpCDD
2,3,7,8-TCDF
Total TCOF
2,3,7,8-TCDD
OCDF
OCDD
M9/1
M9/1
/ig/i
M9/1
M9/1
W3/1
M9/1
M9/1
M9/1
M9/1
ppt
PPt
ppt
PPt
PPt
PPt
PPt
PPt
PPt
PPt
PPt
PPt
ppt
ppt
ppt
PPt
PPt
ppt
PPt
ppt
--
--
<2.8
<2.8
<3.2
<14
--
<2.8
<10
<3.2
<0.32
8.78
127.1
<6.14
37.6
<0.87
<0.91
180.8
36.5
<1.49
289.5
50.3
204.4
668.7
1,291
<0.53
113.0
<12.5
214.8
7,595 1
--
--
430
260
618
179
--
390
650
1,900
65.9
180.4
407.9
10.7
66.9
211.7
73.1
2,388 1,
2,542 1,
292.6
9,932 5,
2,742 1,
8,367 4,
82,636 41,
185,173 93,
112.2
146.7
115.4
1,701
,086,585 547,
..
-.
69
66
134
40
--
48
171
479
33.1
94.6
267.5
8.42
52.2
106.3
37.0
284
289
147.0
111
396
286
652
232
56.4
129.8
64.0
957.9
090
10
37
-.
149
28
..
103
--
--
- -




















    NOTES:
    (1)
    (2)
The sludge data presented are based on the sampling results of three aqueous hazardous waste treaters
with physical/chemical treatment:  2 sites. Sites J and L,  in the EPA-ITD sampling effort and one site
in  the  OSW  sampling  program.     All  samples  were   collected  at  the  discharge  of   sludge
thickening/dewatering  facilities.   One sludge  sample was collected from each  of the EPA-ITD  sampled
sites, 11 sludge samples were collected in the  OSU program.  All sludge data is contained in Appendix
C.

Metals concentrations  in mg/kg wet basis, organics in M9/1,  and dioxins/furans in ppt, as indicated.
All toxicity characteristic leaching  procedure (TCLP) concentrations in
                                                     127

-------
organic compounds were detected in the  sludges.   Eight compounds
were  found  at  concentrations  above  10,000  ng/1,  indicating
significant    removal    of    some    organics    by    chemical
precipitation/sedimentation technologies.  Adsorption on the solids
is a probable removal mechanism. Acetone,  a volatile compound that
showed a relatively high average percent removal, was found  to be
concentrated in the sludge, showing that volatilization is  not the
only removal mechanism for certain volatile pollutants.

     The most significant item in  the  sludge analyses is the  large
number  and  high  concentration  of  dioxins/furans.    Thirteen
individual isomers were identified at concentrations ranging from
<0.32 ppt to 1.087 ppm.   The  isomers included 2,  3, 7, 8-TCDD, the
most toxic dioxin known.  Its concentration in one sludge  was 115
ppt, which  is  extremely high.   No dioxins/furans  analyses were
performed on the raw wastes or the  treated  effluents; however, most
dioxins   are  relatively  insoluble  and  tend  to   adsorb  on
particulates.    Significant  TSS  concentrations  in  the   treated
effluents discharged  from aqueous hazardous  waste treaters  could
indicate   the    discharge   of  significant   concentrations  of
dioxins/furans.


6.3.3  Advanced Treatment

     Three  aqueous hazardous  waste  treaters  operated  advanced
wastewater   treatment  systems.    Only   one  facility  provides
reduction/oxidation    followed    by   chemical    precipitation,
clarification,   sand  filtration,  carbon   adsorption,  biological
treatment,  and polishing ponds   before  discharging directly  to
surface  water.    At  another  facility,   inorganic  wastes are
pretreated with  chemical precipitation  and mechanical filtration
(filter press)   prior  to  mixing with  other wastes.   The combined
wastes  then undergo  biological  treatment,  filtration,  carbon
adsorption,   and polishing in holding  ponds prior to discharge to
a  POTW.   The  third  facility pretreats  cyanide wastes  prior  to
combining  them  with  other  wastes  for   chemical  precipitation,
mechanical filtration (filter press),  sand filtration, and carbon
adsorption prior to discharge to a POTW.


6.3.3.1  Treated Effluent Data

     Table 6-13 presents  summary concentration and percent  removal
data for pollutants found in  the  effluents of advanced treatment
systems.  Even  with biological treatment,  relatively poor removals
of  BOD5,  COD,  and TOC  were  found.   Not only  were  the  percent
removals of the pollutants poor,  but high  effluent concentrations
were the norm.   The advanced treatment systems also provided poor
TSS removals with the effluent concentrations averaging 480  mg/1.
Intermediate data showed that the ponds did not  contribute TSS to
the effluents.   Poor reductions resulted  in high effluent  ammonia

                               128

-------
   TABLE 6-13.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED
TREATMENT SYSTEM EFFLUENTS - AQUEOUS TREATERS SUBCATEGORY(2)
Pollutant
BOD5_, mg/1
COD, mg/1
TOC. mg/1
TSS. mg/1
Ammonia, mg/1
TKN, mg/1
O&G, mg/1
Pheno 1 s , mg/ 1
Cyanide, mg/1
Fluoride, mg/1
Boron
Barium
Iron
Manganese
Zinc
Nickel
Aluminum
Lead
Cadmium
Molybdenum
Tin
Cobalt
Chromium
Copper
Titanium
Silver
Arsenic
Antimony
Mercury
Vanadium
Acetone
Acrolein
Chloroform
Methylene Chloride
Trans-1 , 2 -Dichloro-
ethene
Trichloroethene
Vinyl Acetate
Dichloroethene , 1,1-
Effluent
Minimum
30
250
40
60
0.1
1.5
1.0
0.05
0.02
0.4
3,000
106
361
184
56
686
27
560
<5
66
<13
7.8
60
20
<10
<1
30
14
<0.2
3.2
<50
<50
<10
<10
<10

<10
48
<10
Concentration (1)
Maximum
2,340 1,
5,820 2,
1,500
980
650
1,170
18.2
35.4
0.19
14
15,400 8,
1,090
3,550 1,
2,580 1,
1,600
2,200 1,
857
740
1,400
627
<40
7.8
120
870
<50
<5
124
77
6
3.4
160,000 76,
839
111
30,000 6,
28

12
407
16
Mean Mean 3
013
944
966
480
186
577
9.9
10
0.11
7.4
403
552
946
345
634
285
440
640
303
329
(4)
7.8
84
307
(4)
(4)
76
46
2.1
3.3
621
247
35
015
14.5

10.5
228
11.5
\ Removal (3)
57
63
53
54
57
48
84
48
80
57
43
28
63
50
75
79
50
85
68
56
50
53
82
84
50
50
57
64
88
50
33
0
50
58
68

94
0
49
                             129

-------
      TABLE 6-13.  CONCENTRATIONS OF POLLUTANTS IN ADVANCED
   TREATMENT SYSTEM EFFLUENTS - AQUEOUS TREATERS SUBCATEGORY(2)
                            (Continued)
                      Effluent Concentration(1)

 Pollutant            Minimum   Maximum    Mean   Mean % Removal(3)
Trichloroethane
1,1,2- <10
Tetrachloroe thane ,
1,1,2,2- <10
Dichloroethane ,
1,2- <10
Butanone, 2- (MEK) <50
Thioxanthone 222
Butyl Benzyl
Phthalate <10
Di-n-Butyl Phthalate <10
Trichloroethane ,
1,1,1- <10
Benzene <10
Carbon Tetrachloride <10
Chlorobenzene <10
Ethylbenzene <10
N-Dodecane (N-C12) <10
Tetrachloroethene <10
Toluene <10
Dichloroethane, 1,1- <10
Benzoic Acid <10
P-Cresol <10
Diethyl Ether <50
Isophorone
Phenol <10
Chloro-3-Methyl
Phenol, 4- <10
Alpha-Terpineol <10
0-Cresol <10
Hexanoic Acid <10
2-4-D <5
Aldrin <0.2
Endosulfan II <0.5
Heptachlor <0.2

556

241

78
5,437
293

100
120

1600
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
96
__
<100

<100
548
<10
<10
<5
<0.2
<0.5
<0.2

187

91

27
1,397
258

40
47

328
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
62
5.5
(4)

(4)
\ /
189
<10
<10
<5
<0.2
<0.5
<0.2

47

50

69
82
50

0
0

90
82
78
78
68
79
81
79
49
99
73
12
29
98

48
0
21
£* J.
98
81
U ~L,
91
75
82
OCDF,  ppt
                                            0.15
                               130

-------
     TABLE  6-13.   CONCENTRATIONS OF POLLUTANTS IN ADVANCED
  TREATMENT SYSTEM EFFLUENTS - AQUEOUS TREATERS SUBCATEGORY(2)
                            (Continued)
NOTES:

(1)  All concentrations expressed in p.g/1, unless otherwise noted.

(2)  Data presented  are  the  results of sampling at three aqueous
     hazardous  waste treaters  with advanced  treatment systems:
     Site K provided reduction/oxidation, chemical precipitation,
     clarification,  filtration,  carbon  adsorption,  biological
     treatment and polishing ponds;  Site M treatment included pre-
     treatment   of  inorganic   wastes,  biological   treatment,
     filtration, carbon adsorption,  and polishing; and the OSW site
     pretreated cyanide wastes,  followed by chemical precipitation,
     filtration, and carbon adsorption. All sampling data for these
     three sites are contained  in Appendix C.

(3)  Mean % removal was calculated using the sampling data from all
     three aqueous treaters with advanced treatment systems based
     on the following formula:

                       n

     Mean % Removal = \ '  (mean influent - mean effluent)  x 100
                                     mean influent
                                          n

     Where  mean influent  is the  raw waste  water concentration
     calculated for each site.  Mean effluent  is the final treated
     site effluent  also calculated for each  site.   Influent and
     effluent data for these  sites are contained in Appendix C.

     n = 3, the number  of aqueous hazardous waste treaters with
            advanced treatment  in the data base.

     For  those  pollutants  whose  effluent   concentrations  were
     reported  less  than  the   detection  limit  (for  example,
     ethylbenzene <10 M9/1), the detection limit (10 M9/1) was used
     in the calculation.

(3)  Mean  effluent concentrations  are not  presented  for those
     pollutants where all effluent concentrations were below the
     detection limit and  different detection  limits were reported
     for the three sites.
                                  131

-------
and TKN  concentrations,  but none  of  the treatment  systems were
designed specifically for removal of these pollutants.


Metals

     Iron, manganese, boron, barium, nickel,  and zinc were found
at  concentrations above  1,000  nq/l  in the treated  effluent.
Average removals of these metals  ranged from 28 percent for barium
to 79 percent  for nickel.   The advanced treatment  system at the
first  facility   reported   lower  concentrations   of  aluminum,
manganese,  barium,  chromium,  copper,   iron,  and  nickel  after
intermediate  steps in  the  treatment  system than  in the  final
effluent.      Based   on  mean   effluent   concentrations,   the
physical/chemical  treatment  systems discussed  in  Section  6.3.2
produced lower cadmium,  mercury,  copper,  nickel,  barium,  and lead
concentrations.  Mean effluent concentrations of zinc,  aluminum,
chromium, iron,  and  boron were  lower  in the  advanced  treatment
systems.

Organic Pollutants

     Nineteen  organic pollutants were  detected  in  the  effluents
from the advanced treatment systems, but only 4 had concentrations
above 1,000 ^g/1  compared to 14  in the  physical/chemical system
effluents.  In addition, another 13 organic compounds detected in
the  raw   wastes  were  reported  below  detection levels  in  the
treatment system  effluents.   Average removal of these  compounds
ranged from 8  to  98 percent.  Although 8  of  the  13  compounds are
volatiles, the average percent removals of the  volatiles were lower
than  those  of  the nonvolatiles,  which  indicates  that  removal
mechanisms other than volatilization are effective in the advanced
treatment systems.

     Only five compounds averaged  zero percent  reduction through
the advanced  treatment  systems,  including some with raw  waste
concentrations below  their detection  limits.   Such data may be the
result  of  detention  times  in  the  treatment  systems  and/or
analytical difficulties, both  of  which  affect  the  estimates of
actual removals  of  organic  pollutants  in wastewater  treatment
systems.


6.3.3.2  Residuals Data

     The  concentrations  of  pollutants reported  in  sludges from
advanced treatment systems,   as  shown in Table 6-14,  are limited
to  data   from  only  one   facility,   the   one with   chemical
precipitation,  filtration,  and carbon  adsorption.   Consequently,
the   sludges    are    chemical    sludges   rather   than   the
chemical/biological sludges  generated  by the other two  advanced
treatment systems.

                               132

-------
 TABLE  6-14.   CONCENTRATIONS OF  POLLUTANTS  IN  ADVANCED  TREATMENT
            SYSTEM SLUDGES  - AQUEOUS  TREATERS  SUBCATEGORY(1)
                                   Sludge Sample
                                      Results of TCLP (/tg/l)(3)
Pollutant
Units(2)  Minimum    Maximum
                                                     Mean   Minimum   Maximum    Mean
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
mg/kg
nig/kg
mg/kg
mg/kg
mg/kg
mg/kg
2,900
0.068
380
790
1,400
4,000
12,000
23,000
50,000
1,300
9,300
35,000
7,200
11,700
39,300
973
5,700
17,700
Cyanide
 mg/kg
400
          950
                   667
Acetone
Methylene Chloride
Trichloroethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
Naphthalene
Bis(2-Ethylhexyl)Phthalate
Di-N-Butyl Phthalate
Trichloroethane, 1,1,1-
Tetrachloroethene
Chloroform
NOTES:
(1) Data presented are
M9/1
M9/1 61,000
M9/1 73,000
Mg/l 290,000 1,
Mg/l 11,000
Mg/l 55,000
Mg/l 300,000
Mg/ i
Mg/l 22,000
M9/ I
M9/1 110,000
M9/1 74,000
M9/1

the results of sludge
--
79,000
400,000
400,000
34,000
110,000
720,000
12,000
200,000
15,000
160,000
100,000
—

samples
260,000
70,000
194,300
756,700
20,000
79,300
530,000
--
111,000
--
135,000
87,000


taken from
--
-- 2,800
-- 1,700
-- 7,200
240
520
-- 3,200
--
--
--
3,100
660
300

the OSU sampling facility wi
       treatment.  Treatment at this  facility  includes pretreatment of  cyanide  wastes prior to chemical
       precipitation, filtration,  and carbon adsorption.  The sludge samples were  collected from the sludge
       filter press.

 (2)    Metals concentrations in mg/kg wet  basis  and organics in ;tg/l.  All TCLP concentrations in M9/1.

 (3)    TCLP = toxicity leaching characteristic procedure.
                                                 133

-------
     Cadmium,   chromium,   copper,   and  zinc   were   found  at
concentrations  above  10,000  mg/kg  in  the  sludges.    Sludge
concentrations of 12  organic compounds were also  high.  Because
the sludges only were tested for 6 metals and 93 organic  compounds,
it is likely that  other organics  and metals also were present.  In
addition,  high  detection limits  resulted in only 12  of  the 93
organics tested being found at reportable concentrations.

     The  TCLP  concentrations  of  the  organic  compounds  were
relatively   low,  considering  the   corresponding  compositional
analyses.    No  dioxins/furans  analyses  were  performed on the
sludges.


6.3.4  Conclusions

     Aqueous hazardous waste treatment  systems range from chemical
precipitation/sedimentation  units  to  advanced   secondary  and
tertiary treatment systems.

     Although the physical/chemical treatment technologies in-place
at aqueous  hazardous  waste treaters are  designed  for removal of
metals and other inorganic pollutants, the wastes accepted by these
facilities contain significant quantities of toxic organics that
pass through  the  treatment  systems,  receiving  limited  treatment.
The poor treatment received by organics is reflected in the BODf>,
TOC,  and COD removals.    Large  reductions in  heavy  metals are
achieved by  the treatment  systems,  even  for metals  found in low
concentrations in the raw wastes.  Only five metals were found in
concentrations above 1,000 M9/1 in treated effluent.

     Compared to the physical/chemical treatment systems in-place
at some  aqueous hazardous  waste  treaters, the  advanced treatment
systems are more effective  in removing  organic compounds; however,
high effluent concentrations of organic compounds are common even
with advanced treatment.   This  conclusion  is supported by high
effluent concentrations of indicator compounds such as  BOD5, TOC,
and COD, which show relatively poor removals.   Advanced treatment
systems  demonstrated  metals  removal  efficiencies and effluent
concentrations  similar to  those  achieved  by  physical/chemical
treatment systems.

     Due to detention times  in treatment systems  and the limited
number of samples collected at each facility,  it was difficult to
pair influent and effluent concentrations of pollutants to estimate
percent  removals.    In  an  attempt  to  overcome   this obstacle,
influent and effluent concentrations were averaged, but even this
procedure  resulted  in negative  percent removals  in  some cases.
Negative percent removals were assumed to be zero percent removal
when discussing the effectiveness of treatment technologies.
                               134

-------
     Both  physical/chemical  and  advanced  treatment technologies
provided relatively poor removal  of BOD5, TOC, COD, TSS, ammonia,
and TKN.   High effluent concentrations  of  other pollutants also
were  found.    These  results are typical  for physical/chemical
treatment  systems  designed  to  remove  inorganic  pollutants,
primarily metals.  The relatively poor removal of TOC and BOD5. by
advanced treatment systems using biological treatment and/or carbon
adsorption indicates the potential for discharge  of poorly treated
hazardous wastes to POTWs or surface waters.

     Based  on  the plants  sampled,   many  of  the  toxic  organic
pollutants accepted by aqueous hazardous waste treatment facilities
were  not  effectively removed by physical/chemical  or  advanced
treatment  systems.  Effluent concentrations of individual organic
compounds  can exceed 10,000  M9/1/  even with advanced treatment
technologies  such as  carbon adsorption.  Biological treatment was
also  relatively  ineffective in  the  treatment  of some  organic
compounds.   However,  better  performance is  expected  from these
treatment  technologies,  and  the  poor performance observed in the
sampled plants  is believed attributed to the  small data base.

     No  significant  differences  between  the  effectiveness  of
physical/chemical  and advanced  treatment technologies in removal
of metals was demonstrated by the treatment systems investigated.
The advanced  treatment  systems  demonstrated  better removals and
lower  effluent  concentrations  for  certain  metals,  while  the
physical/chemical treatment systems were better for others. Whether
these results are  indicative of  the effectiveness of the types of
treatment  technologies   or  the  result  of  raw  waste types  and
concentrations  of metals in them has not been established.

     A  critical question raised by  the  data presented  in this
section is the  potential for the discharge of dioxins/furans from
aqueous hazardous waste treaters to POTWs and surface waters.  The
effluent samples were  not tested  for dioxins/furans,  but  extremely
high concentration of a large number of isomers were found in the
sludges.  Dioxins/£uxans are  relatively insoluble in water and tend
to adsorb  on particulates.  High effluent TSS concentrations were
found from both physical/chemical and advanced treatment systems,
which indicates the potential for the discharge of these isomers.
Sampling   and  testing   of  treatment   system   effluents  for
dioxins/furans  is necessary  to  establish the  concentrations of
these  compounds  in   treated  effluent and  the  effectiveness of
various treatment systems for their removal.
                               135

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           7.   COST OF WASTEWATER CONTROL AND TREATMENT
     This section presents estimates for the cost of implementation
of  wastewater treatment control  for  each of  the  subcategories
included in the hazardous waste treatment (HWT)  industry.  The cost
estimates provided the basis for the determination of the probable
economic impact of regulation.

     To arrive at the cost estimates  presented in  this section,
specific waste treatment technologies were selected that correspond
to the common types of facilities operating within the HWT industry
as found in Table  7-1.  The  raw wastewater characteristics selected
were based on the range of pollutant  concentrations found during
sampling  efforts.    Wastewater  flow   rates used  in  sizing  the
eguipment are  typical  rates  found  within   treatment systems used
for costing.

     The  cost estimates  include  both investment  and  operating
costs.  Investment costs were determined  by estimating the costs
of individual unit operations.  These estimates were derived from
development documents for industries treating similar wastes, other
U.S.  Environmental  Protection Agency  (EPA) reference  material,
textbooks,  manufacturer's  literature,  and vendor  quotations.  A
piping cost for intercomponent piping,  valves, and piping required
to transfer  the wastewater  to the  treatment system was estimated
as a percentage (10%) of the total equipment cost.

     As a  part of  the investment  cost,   it was  assumed  that  a
building would be  necessary to:  (1) house the majority of the unit
operations,  (2)   house the   system  instrumentation,  (3)  store
treatment  chemicals  and other supplies,  and  (4)  as a  base  for
operation and maintenance activities.

     Several other cost elements were estimated  as a percentage of
the  total  capital costs.    An  equipment,  piping,   and  building
contingency  of  10  percent  was  used  to  account  for  varied
requirements at specific locations.  In  addition,  an engineering
design fee of  10 percent was  included  to  account  for the overall
design of the process and engineering supervision required during
installation and  start-up of the equipment.  Inspection fees (2%)
also were added to the total investment cost (TIC).

     Operating costs  were estimated by adding together the expected
annual costs for various operating cost  elements. A labor estimate
was made based on expected requirements  for the  entire facility
rather than for individual  units.   An overhead rate of 50 percent
was added  to the salaries  to account  for  employee  benefits and
employment costs  (e.g.,  social  security,  medical  benefits,  and
unemployment tax)  incurred  by the  facility.    Energy  costs were
calculated  based  on  the  expected  requirements   for  each  unit

                               136

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  TABLE  7-1.   DESIGN  BASIS  FOR TREATMENT  SYSTEM  COST  ESTIMATES




Aqueous Hazardous Waste Treaters Subcategory

     Design flow rate of 45,500 gpd (see Figure 7-1)

     Facility operates 24 h/d, 5 d/wk, 260 d/y
             no weekend operation

     Waste volumes received  are evenly divided into five types each
     with an average  flow of 10,000 gpd:

            Chromate wastes
            Metal wastes
            Cyanide wastes
            Oily wastes
         •  Organic wastes

     The characteristics of each waste category are as follows:

              chromate wastes           cyanide waste
              1297 mg/1 Cr +6           225 mg/1 CN

              metal wastes              oily waste unspecified
              113 mg/1 Cd
              753 mg/1 Cu               organic waste
              3,286 mg/1 Zn             1,000 mg/1 COD
              1,577 mg/1 Ni
              107 mg/1 Pb

Leachate Treatment Subcateaorv

     Design flow of 30,000 gpd (see Figure 7-2)

     Facility operates 24 h/d, 5 d/wk, 260 d/yr
             no weekend generation

     Weekend flow is stored in aerated equalization tank  (Required
     since leachate  is  continuously generated and only treated 5
     days/week)

     Raw waste characteristics are as  follows:

              pH = 7.0
              COD = 500-25,000 mg/1
              Total metals = 426 mg/1
                                137

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  TABLE 7-1.  DESIGN BASIS FOR TREATMENT  SYSTEM COST ESTIMATES
                           (Continued)
Scrubber Wastewater Subcategory

     Design flow of 900,000 gpd/93,000 gpd (see Figure 7-3)

     Facility operates 24 h/d,  5 d/wk, 300 d/yr
             no weekend operation

     The waste volume of scrubber blowdown was 900,000 gpd

     Raw waste characteristics  are as follows:

         pH = 0.1 to 2.0
         TSS = 10,000 mg/1
         Temp = 80°C
         Total Metals = 424 mg/1
                               138

-------
operation  considering  hydraulic loading  and  air requirements.
Energy costs primarily  include electrical requirements for pumps,
blowers,  and mixers.    Chemical and material  costs also  were
determined for  each  unit operation based on  flow rate and waste
characteristics.  Sludge disposal  costs were based on calculated
sludge volumes, current average  disposal rates for hazardous and
nonhazardous wastes,  and a unit cost of $.27 per gallon.  This unit
cost was  on the  low side of the  wide  range  of  reported sludge
disposal costs.  Use of a low cost,  for purposes of this study, is
appropriate since owners/operators of HWT facilities are likely to
dispose of the sludge  on-site   or  choose a  least-cost  means of
disposal.   Several other operating cost  elements were included as
a percentage of the TIC, including administration  (5%), laboratory
(2%),  and taxes (1%).

     All  investment  and operating costs  were adjusted  to  1987
(March) dollars using the  CE plant cost  index.

     The  three  model  treatment systems  used  as a basis  for
estimating  the cost of wastewater  treatment for  each of  the
industry subcategories  are presented in Figures 7-1 through 7-3.
A summary of the cost estimates is shown in Tables  7-2  through 7-4.
Assumptions  used  in estimating the  treatment  costs for  each
subcategory are contained  in Appendix D.


7-1  AQUEOUS THEATERS SUBCATEGORY

     Unlike  the  other   subcategories  of the  HWT  industry,  the
production  facility  cannot  be   separated   from   the  wastewater
treatment   system    in   the    aqueous   treaters   subcategory.
Consequently, the pollution control and treatment technology costs
are the same as the  costs  for the actual production facility. For
an average size facility (45,500 gpd) as shown  in  Figure 7-1, the
investment cost was estimated at  $767,000.  Annual  operating costs
are estimated at  $325,000  per year.
7.2  LEACHATE TREATMENT SUBCATEGORY

     Based on average flow of 30,000 gpd, the investment cost for
the  model  leachate  treatment  facility  shown  in Figure  7-2 was
estimated at $806,000.  Annual  operating costs were approximately
$286,000 per year.  The model facility  is designed to remove both
inorganic and organic BAT pollutants.  Costs for less sophisticated
treatment systems can be estimated by eliminating individual unit
process costs from Table 7-3.
                               139

-------
 Chrome-
Storage/
 Equal
                 Chrome Wastes
                 10,000 gpd
 Metals
Storage/
 Equal.
                Metal Wastes
                10.000 gpd
                                                Cyanide
                                               Storage/
                                                Equal.
                                                               Cyanide Wastes
                                                               10.000 gpd
Oily Waste
 Storage
  Equal.
                                         
                                       •JF
»,«..-,    |    r-
                 Oils Wastes
                 10,000 gpd
                                                                       NaOH
       Chrome Reduction

              Liquid Return
           Neutralization/
            Precipitation
                                     Polymer
                Organic Wastes
                10.000 gpd
 Organic
Storage/
 Equal.
                              Cyanide Oxidation    Oil Separator
                                                     Flocculation/
                                                     Clarification
                                        Solids
                                                                               Flotation
                                                                               Settling Tank
                                                                 Backwash
                                                                                               Solids
                                                                I  '
                                    Sludge Thickeninp
                                Solids
                                        Filter Press
                                        Dewatered Sludge
                                           To Disposal
                                                                                                    Wastewater
                                                                                                     Discharge
                                                                     Filtration
                                                                Carbon
                                                              Adsorption
                                 Figure 7-1. Model Aqueous Waste Treatment System

-------
Raw Leachate Acid
 30,000 gpd
                                                            Waste water
                                                             Discharge
                                        Figure 7-2. Model Leachate Treatment System

-------
Make-up
 Water
              Scrubber
     Wastewater
      Discharge
     93,000 gpd
                                      Lime
                               900,000
                                                                        Polymer
                                       11
                                       Neutralization
                               Backwash
                                                     Cooling Lagoon
                                                    Cooling Lagoon
                                                                          Flocculation/
                                                                           Clarification
                                                                                 Solids
                   Carbon
                 Adsorption
Filtration
                                                                                                     Return to Neutralization
                                                             Solids
                                                           Thickener
-


\
u




Filter
— *• Press t
Neutra
z_A
,. 1 _^ Sludge to
84J "* Disposal
                            Figure 7-3. Model Scrubber Wastewater Treatment System

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        TABLE  7-2.   MODEL AQUEOUS  TREATMENT  SYSTEM  COSTS




Investment Cost

  System Component                                   Cost. 1987 $

     Storage/Equalization  (5-5,000 gal)                  23,500
     Chrome Reduction                                    19,600
     Cyanide Oxidation                                   18,600
     Neutralization/Precipitation                        29,400
     Flocculation/Clarification                          39,200
     Filtration                                          45,500
     Carbon Adsorption                                  260,000
     Sludge Storage/Thickening                           21,700
     Filter Press                                        51,450
     Oil Separator                                       34,600
     Equipment Subtotal 	> 543,550
     Piping (10% of equipment)                           54,355
     Building  (1,000 sq.ft. @ $75/sq.ft.)                75,000
     Subtotal for Building and Equipment 	> 618,550
     Contingency (10% of B&E subtotal)                   61,855
     Engineering Design (10% of B&E subtotal)            61,855
     Inspection Fees (2% of B&E subtotal)                12,371
     Administration/Legal Fees (2% of subtotal)          12,371
     Total Investment Cost (TIC)  	> 767,002

Operating Cost

  Operating Cost Element                      Annual Cost. 1987 $

     O&M Labor (8,000 hrs @ $18/hr, include 50% OH)       91,900
     Energy                                               5,100
     Chemicals and Materials                            103,600
     Sludge Disposal                                     25,000
     Administration  (5% of TIC)                          38,350
     Laboratory (2% of TIC)                              15,340
     Equipment Replacement (5% of TIC)                   38,350
     Insurance and Taxes  (1% of TIC)                      7,670
     Total Operating Cost  	> 325,310
                               143

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        TABLE 7-3.   MODEL LEACHATE TREATMENT SYSTEM COSTS
Investment Cost

  System Component                                   Cost, 1987 $

     Aerated Equalization                                87,100
     Mixing                                              22,500
     Flocculation/Clarification                          30,400
     pH Adjustment                                       22,500
     Air Stripping                                       29,890
     Neutralization                                      22,500
     Activated Sludge/Clarification                      80,000
     Filtration                                          33,500
     Carbon Adsorption                                  135,300
     Sludge Thickener                                    19,600
     Filter Press                                        39,200
     Equipment Subtotal 	> 522,490
     Piping (10% of equipment)                            52,249
     Building (1,000 sq.ft. @ $75/sq.ft.)                 75,000
     Subtotal for Building and Equipment 	>  64,739
     Contingency (10% of B&E subtotal)                   64,974
     Engineering Design (10% of B&E subtotal)            64,974
     Inspection Fees (2% of B&E Subtotal)                 12,995
     Administrative/Legal Fees (2% of subtotal)          12,995
     Total Investment Cost (TIC)  	> 805,676

Operating Cost

  Operating Cost Element                      Annual Cost. 1987 $

     O&M Labor (8,000 hrs @ $18/hr, include 50% OH)     144,000
     Energy                                              16,100
     Chemicals and Materials                              6,700
     Sludge Disposal                                     14,000
     Administration (5% of TIC)                          40,284
     Laboratory (2% of TIC)                              16,114
     Equipment Replacement (5% of TIC)                   40,284
     Insurance and Taxes (1% of TIC)                      8,057
     Total Operating Cost 	> 285,538
                               144

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        TABLE 7-4.  MODEL SCRUBBER TREATMENT SYSTEM COSTS
Investment Cost
  System Component                                  Cost. 1987 $

     Neutralization/Clarification                       571,000
     Cooling Lagoons (2-3 ft deep x 142'x 142')          60,400
     Fil'tration                                          65,700
     Carbon Adsorption                                  335,000
     Sludge Thickener                                    22,500
     Filter Press                                        46,000
     Equipment Subtotal  	> 1,032,100
     Piping (10% of equipment)                          103,210
     Building (1,000 sq. ft. @ $75/sq.  ft.)              75,000
     Subtotal for Building and Equipment 	> 1,210,310
     Contingency (10% of B&E subtotal)                  121,031
     Engineering design  (10% of B&E subtotal)            24,206
     Inspection Fees (2% of B&E subtotal)                24,206
     Adirtinistration/Legal Fees (2% of subtotal)          24,206
     Total Investment Cost (TIC)  	> 1,500,784


Operating Cost

  Operating Cost Element                      Annual Cost. 1987 $

     O&M Labor ($18/hr,  including 50% OH)               144,000
     Energy                                              13,800
     Chemicals and Materials                              9,500
     Sludge Disposal                                     18,252
     Administration (5% of TIC)                          75,039
     Laboratory (2% of TIC)                              30,016
     Equipment Replacement (5% of TIC)                   75,039
     Insurance and Taxes (1% of TIC)                     15,008
     Total Operating Cost 	>   380,654
                               145

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7.3  SCRUBBER WASTEWATER SUBCATEGORY

     For the scrubber wastewater subcategory,  two cost estimates
were  calculated,  as  shown in  Table  7-4.    The first  estimate
included the investment  and operating cost for the entire scrubber
wastewater    treatment     system,    including    neutralization/
clarification,  cooling  lagoons, filtration,  carbon  adsorption,
sludge thickening,  and filter press, as shown in Figure  7-3.  These
system components,  except  for filtration and  carbon  adsorption,
were  related  to the water reclamation system of the  industrial
process rather  than the wastewater  discharge  system.   Therefore,
the second cost estimate only considered the wastewater portion of
the facility.

     The  model  scrubber  wastewater  treatment  system  assumed
approximately  10  percent  blowdown  rate  with treatment  prior to
discharge.    Investment costs  for the  treatment  system  were
estimated  to  be  $1,501,000  and   annual  operating  costs  were
estimated at $381,000 per year.


7.4  ECONOMIC ASSESSMENT AND  COST EFFECTIVENESS

     The  purpose  of this  subsection  is to assess the  economic
impacts that possible regulations would have on the HWT industry.
An economic assessment  is  presented that compares the  annualized
cost  of  possible regulations to  revenues  currently realized by
typical  facilities  in  the  industry.    Cost-effectiveness  was
determined  to  identify   the   incremental   annualized  cost  of
subcategorical  pollution  control options  per incremental  pound
equivalent of pollutant removed by that control option.

     For purposes of an economic evaluation,  four model plants were
developed, representing an incinerator,  a municipal landfill,  a
hazardous waste landfill,  and an  aqueous  waste treater.   Since
detailed economic  and technical  data  were not available at that
time,  these models  are  only for  preliminary economic  assessment.
Capital and operating costs for typically sized  model  plants are
presented in  Table 7-5.   Capital  and operating  and  maintenance
(O&M)  costs were presented earlier  in  this  section.  The cost of
land was estimated at 20 percent of the capital costs,  and annual
monitoring costs were estimated  at $5,000.    The  annualized cost
equals the sum of O&M and monitoring costs, plus the annual portion
of capital and  land costs, assuming a  capital recovery factor of
0.26  (which corresponds  to a discount  rate of 10 percent  and 5
years).  These costs also are presented in Table 7-5.


7-4.1   Preliminary Economic Impact  Assessment

     Economic  assessment impacts  were measured  by the  ratio of
treatment costs to revenues.   Using a high,  low,  and average fee,

                               146

-------
              TABLE  7-5.   MODEL FACILITIES  AND COSTING*
                  Model                     Control Cost ($1,000)
Subcategory     Capacity    Investment   Land   O&M  Monitor  Annual**
Incinerator

Landfill
  Municipal

  Hazardous
  Waste
  Landfill
18,000 mt/y


62 acres



62 acres
Aqueous Treater 45,500 gpd
                for 260 d/y
1501
 806
 806
                 767
300   381
161   286
161   286
           153   325
854
542
542
                       569
*    These model plant sizes are used for preliminary economic
     analysis only-

**   Capital recovery factor is 0.26.
                                  147

-------
revenues were  estimated  for  each  model facility  based  on its
capacity as follows (Ref.  31):

          Incinerator - $26 to $3,300 per metric ton, or an average
          $1,000 per metric ton ($3.80 per gallon)

          Aqueous waste treater -  $0.12 to $6  per  gallon,  or an
          average $1.60 per gallon

          Hazardous waste landfill -  $76  to  $658 per  metric ton,
          or an average $120 per metric ton

          Municipal landfills - $3  to $41 per  metric ton,  or an
          average $13 per metric ton


     Revenue and  treatment  cost estimates were calculated  on an
annual basis for incinerators and agueous treaters.   However, for
hazardous  and  municipal  landfills,  monitoring and treatment of
leachate must  continue for some time after  dumping,  as  long as
toxic leachate is generated.  The  cost of leachate  treatment was
assumed to continue for 20 years after the initial  dumping, even
if the site is  closed.   The revenue for the 62-acre model landfill
assumes that the landfill is filled  to its lifetime capacity (62
acres times 12,100 metric ton per acre) in the initial year.  The
present value  of the  lifetime  leachate treatment  costs  include
initial capital and land costs of $967,000, as shown in Table 7-5,
plus the present  value  of O&M and monitoring for the next 20 years,
discounted at 10 percent.

     Table 7-6  presents the estimates of treatment cost in relation
to revenues.  For incinerators and aqueous treaters,  the treatment
costs and revenues are  in annual terms.   While the  average ratio
for incinerators was 4.7 percent, the ratio  ranges  from a low of
1.4 percent  for  incinerators  charging the highest  fees  to 182.5
percent for incinerators charging the lowest  fees.   The impact of
aqueous treaters was smaller:   the average ratio was 3.0 percent,
with a range from 0.8  percent for  treaters charging high fees to
40.6 percent for treaters charging low fees.

     For landfills,  the revenue  from  landfilling a given amount of
material was compared to the  lifetime cost  of treatment.   For
hazardous  waste  landfills,  the ratio  of the  lifetime  cost of
treatment to revenue ranges from 0.7  to 6.0  percent with a ratio
of 3.8 percent for a landfill charging average fees.   Because of
the low tipping fees at municipal landfills, the ratio of leachate
treatment cost to  revenues  could be high,  if  such treatment is
needed.  The ratio  of lifetime treatment cost  to revenue ranges
from 11.2 to 149.7 percent, with a cost to revenue  ratio of 35.5
percent for those charging average fees.
                               148

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TABLE 7-6
MODEL PLANTS OF HAZARDOUS  WASTE TREATMENT  FACILITIES
   AND CONTROL COST1 TO  REVENUE COMPARISON
Subcategory
Incinerator
Capacity Service
18,000 mt/y High
($/mt)
Average

Landfill
Municipal

Hazardous
waste
landfill
Aqueous
Treater

Low
62 acres High

($/mt)
Average
Low
62 acres High

($/mt)
Average
Low
45,500 gpd High

($/g>
for 260d/y Average
Low

fee
3300
1000
26
41
13
3
658
120
76
6
1.6
0.12
Revenu
High
Average
Low
High
Average
Low
Control cost
($000) ($000)
0
0
0
30700
9700
2300
High 495630
Average
Low
High
Average
Low
90000
57000
71000
18900
1400
annually
annually 854
annual ly
life
life 3444
life
life
life 3444
life
annually
annually 569
annually
annually
annually
annually
life
life
life
life
life
life
annually
annually
annually
Control cost
as % of fee
(or revenue)
1
4
182
11
35
149
0
3
6
0
3
40
.4
.7
.5
.2
.5
.7
.7
.8
.0
.8
.0
.6



**
**
**
**
**
**



  **
    Conparing life cycle cost with initial revenue (assuming a discount rate of 10 % in 20 years)
                                     149

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     These ratios  were  based on  tentative  data.   The municipal
landfill results showed that only a  small  fraction (3.7 percent)
were expected to require leachate treatment.  This analysis should
be further qualified because the  wastewater treatment costs were
assumed to be independent of the types of hazardous waste treated,
so that  for  wastes  having low  disposal charges,  the  ratio  of
wastewater treatment  costs to revenue  were high.   This  can  be
misleading.   For  example,  in the case of  incinerators,  scrubber
water  from incinerating highly  toxic  wastes  is more  likely  to
require treatment than scrubber water from  incinerating high BTU
wastes.

     Based on this model plant  analysis,  the cost  of treatment
technologies  appear to be modest  in  relation to  revenue received
by commercial hazardous  waste  treatment facilities  with average
fees.  However, this is not the case for municipal landfills.


7.4.2  Cost-Effectiveness

     Cost-effectiveness  (CE)  is  defined   as  the  incremental
annualized  cost of a pollution control  option in an industry or
industry subcategory per increments  pound-equivalent of pollutant
removed  by  that  control  option.   The analysis  accounts  for
differences in toxicity among the pollutants with toxic weighing
factors (TWF) based on water quality criteria  to protect aquatic
and  human  health.   Because concentration  data  are  not  always
available for many priority and nonpriority hazardous pollutants,
incremental removal may be underestimated in this preliminary CE
calculation.   A  CE analysis  was presented  for each subcategory,
based  on   performance  data  collected  by   EPA-ITD  for  the  HWT
industry.    No  distinction  was   made  regarding  direct/indirect
discharge.    The methodology for  calculating  cost  effectiveness
follows that  employed  for the  Organic Chemicals  Plastics  and
Synthetic Fibers (OCPSF)  category.


7.4.2.1  Scrubber Wastewater Systems

     The control technology  shown in Figure 7-3  consists  of two
parts:    (1)  all  units  between  neutralization  and  cooling pond
inclusive - physical/chemical treatment, and (2)  units downstream
of  the  cooling  pond-filtration/carbon  adsorption.    For  164
incinerators nationwide producing scrubber wastewater, the annual
wastewater flow was 3,966  million gallons.   Table  7-7 shows the
data used  and the step-by-step calculations  for each pollutant.
The incremental annual per plant treatment cost  of $854,000 applied
to each of the 164 plants  gave an annual industry-wide treatment
cost of $140  million.   After calculating the  sum of incremental
removals (PE),  a  CE of $44.68 per  pound equivalent removed was
calculated.   After  treatment,  the  scrubber  wastewater  can  be
reused, thus  avoiding  costs incurred  from obtaining  new water.

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  TABLE 7-7  COST-EFFECTIVENESS CALCULATION  FOR
      SCRUBBER  WASTEWATER TREATMENT  SYSTEMS
Number of plants (N)
Wastewater flow (gpd) a each plant (q)
Number of days/year in operation (d)
Annual flow (mgy) for all plants N x
Organic Raw waste
No.
1.
2.
3.
4.
5.
6.
7.

pollutant name cone.
Acetone
Benzene
Bromoform
Fluoranthene
N-Nitrosodi-N-Propylamine
Pyrene
Thioxanthone
Sum 5
(ppb)
65
61
15
109
907
326
4067
,550
q x d
164
93,000
260
3,966
Advanced treatment
Weighted %
TWF cone. (ppb)
0
0.848
0.0357
0.104
0.452
0.146
0

Annual loading for all flow 184,000
No.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.








Metallic pollutant name
Antimony
Arsenic
Cadmium
Chromium
Copper

1500
1040
600
970
6430
Lead 21200
Nickel
2310
Zinc 159000
Mercury
Selenium
Thallium
Sum 193
Annual loading for all flow 6,385
=================================
Organics plus metals 6,569
Incremental removal (PE) for 164
Annualized costs for all plants
CE ($/PE)
3 each plant: investment ($)
71
6.6
11
,050
,000

0.0036
32.0295
5.09
0.0267
0.467
1.75
0.114
0.119
505.026
0.16
0.257

3,
0
51.7
0.5
11.3
410.0
47.6
0
521
17,000

5.4
33310.7
3054.0
25.9
3002.8
37100.0
263.3
18921.0
35856.8
1.1
2.8
95,683
164,000
removal
na
na
na
83
98
94
90



90
99
89
99
99
99
89
99
99
na
na


efflu. cone.
(ppb)
65
61
15
18.5
18.1
19.6
406.7
604
184,000

150.0
10.4
66.0
9.7
64.3
212.0
254.1
1590.0
0.7
6.6
11.0
2,357
78,000
wtd.
0
51.7
0.5
1.9
8.2
2.9
0.0
65
2,000

0.5
333.1
335.9
0.3
30.0
371.0
29.0
189.2
358.6
1.1
2.8
1,289
43,000
=====================================================
,000
plants



3,



1,
land costs (20% of above) ($)

O&M cost ($/y)


monitoring cost ($/y)
annual ized cost ($/y)


Credit in recycled scrubber water
CE ($/PE) with credit in recycled
a $1.
2 per 1000
181,000



501,000
300,200
381,000
5,000
854,312
gal Ions




















scrubber water
45,000
3,136,000
140,107,000
44.68





35,818,000
33.26
Data sources: raw waste cone.(Tables 5-13 & 5-14), performance (Table 6-9).
          na  not analysed.
                          151

-------
With  credit  for  water  reuse,  CE  would be  $33.26  per  pound
equivalent.  In the calculation, it  was  assumed  that 700,000 gpd
of water from treatment are reused,  with a value of $1.20 per 1,000
gallons.


7.4.2.2  Leachate Treatment Systems

     Candidate control technology for the leachate treatment system
is air  stripping before an activated sludge  process,  followed by
filtration/carbon adsorption.   For  528 leachate collection systems
in the  United States, the annual leachate flow was  4,114 million
gallons.   Table  7-8 presents  the  data and calculations  for the
system.  It should be noted that the Table5-8 was calculated using
unedited data from Chapter 5.   The  data shown in Chapter 5 do not
include "non-detects."

     Because many pollutants are not always present in all leachate
systems, a probability was used to  represent the  likelihood of the
occurrence of a  pollutant  in  the  leachate system.   For example,
methylene  chloride  was  observed in  more  than  50 percent  of the
samples in five out  of six studies; the occurrence probability was
5/6 or  0.83.  The probability of occurrence for each pollutant is
also shown in Table 7-8.

     This analysis incorporated the findings of the EPA Office of
Air Quality Planning and Standards  (OAQPS) by explicitly assigning
removal efficiencies of  air stripping and aerated equalization for
removing  VOCs  (Ref.  32) .     Organic  priority  pollutants  were
classified into  three  groups;  High-Henry's law  constant,  Medium
Henry's law  constant, and Low-Henry's  law constant  (Appendix H).
The analysis  assumed that the  air  stripping/aerated equalization
removed and captured 90 percent of  the first group,  70 percent of
the second group, and none  of  the  third group.  The  CE for this
control option was  $7.66  per  pound  equivalent  removed.   If the
volatilized pollutants were not captured,  then the  CE was $71.60
per pound equivalent removed.


7.4.2.3  Aqueous Hazardous Waste Treaters

     The model plant for  aqueous waste treaters was  composed of
processes treating five  wastestreams, each contributing 20 percent
of the wastewater flow.  Control option was pretreatment (including
chromium reduction,  cyanide destruction, oil skimming, and peroxide
oxidation),  followed  by  flocculation/clarification.    For  602
aqueous hazardous waste treaters in the United States discharging
wastewater, the annual  flow was 7,122  million gallons.  Table 7-9
summarizes  the  data   and  the  calculations.     Using  removal
efficiencies based on data collected  for this analysis, the CE for
this control option was $11.17  per  pound equivalent removed.


                               152

-------
TABLE 7-8 COST-EFFECTIVENESS CALCULATION FOR
         LEACHATE TREATMENT SYSTEMS
Number of plants (N)
Uastewater flow (gpd)

3 each plant (q)
Mumber of days/year in operation (d)*
Annual flow (mgy) for



No. Pollutant
01. CH2CL2 (METH)
02. DCB, 1,2-
03. TCA, 1,1,1-
04. TCE
05. Chloroform
06. Chlorobenz.
07. OCA, 1,2-
08. OCA, 1,1-
09. DCB, 1.4-
10. TetraCE
11. T,-1,2-DCE
12. DCB, 1,3-
13. CCL4
14. TCA, 1,1,2-
15. DCPP, 1,2-
16. Chloronapthal
17. Chloroethane
18. Vinyl chloride
19. TCA, 1,1,2,2-
20. Methyl bromide
21. Methyl chloride
22. DCE, 1,1-
23. DCDFM
24. Toluene
25. Napthalene
26. Benzene
27. Ethylbenzene
28. Phenanthrene
29. Acenaphthylene
30. Nitrobenzene
31. Anthracene
32. Acenaphthene
33. Fluoranthene
34. C-3-methylphen
35. Nitrophenol, 4-
36. Isophorone
37. Di-n-butylphthalate
38. Bis(2-eh) phthalate
39. Dimethyl phthalate
40. Di-n-oct phthalate
41. Pyrene
42. Benzo(a)anthracene
43. Benzo(b)fluoranthen
all plants = N x

Toxic
Weighting Proba-
Factor bility
2.9470000 0.83
0.0170000 0.15
0.0003000 0.15
0.2070000 0.15
2.9520000 0.15
0.0115000 0.15
0.5960000 0.15
0.0005600 0.15
0.0213000 0.15
0.7070000 0.15
0.0005000 0.15
0.0180000 0.15
1.4000000 0.15
0.9340000 0.15
0.0006900 0.15
0.3500000 0.15
0.0000000 0.15
0.2800000 0.15
3.2940000 0.15
2.9470000 0.15
2.9470000 0.15
16.9700000 0.15
0.0357000 0.15
0.0004000 0.83
0.0090300 0.15
0.8480000 0.83
0.0040000 0.5
0.0281000 0.15
0.0660000 0.15
0.0002830 0.15
0.2440000 0.15
0.9210000 0.15
0.1040000 0.15
0.1806000 0.15
0.0135000 0.15
0.0000100 0.15
0.0001650 0.15
2.1866700 0.15
0.0000179 0.15
0.8115900 0.15
0.1460000 0.15
56.3590000 0.15
26.0470000 0.15
528
30,000
260
q X d 4,118
Observed
sample
cone.
(PPb)
20135
7839
5051
8530
3769
3288
13990
394
1687
6873
387
410
7763
15898
54
46
57
189
114097
170
170
99
287
9552
1210
569
3769
69
56
15
20
45
24
14
17
1133
189
934
517
22
25
14
11











	 „ 	 	 Advanced treatment inciuumy
modified air stripping and
Raw waste
Expected cone.
(ppm)
16712
1176
758
1280
565
493
2099
59
253
1031
58
62
1164
2385
8
7
9
28
17115
26
26
15
43
7928
182
472
1885
10
8
2
3
7
4
2
3
170
28
140
78
3
4
2
2


wtd.
49250
20
0
265
1669
6
1251
0
5
729
0
1
1630
2227
0
2
0
8
56375
75
75
252
2
3
2
400
8
0
1
0
1
6
0
0
0
0
0
306
0
3
1
118
43
aerated

Removal
0.7
0.7
0.9
0.9
0.9
0.9
0.7
0.9
0.9
0.9
0.9
0.9
0.9
0.7
0.7
na
0.9
0.9
0.7
0.9
0.9
0.9
0.9
0.92
0.7
0.9
0.9
0.7
0.7
na
na
0.7
na
na
na
na
na
na
na
na
na
na
na
equalization
effluent cone
(ppb)
5014
353
76
128
57
49
630
6
25
103
6
6
116
715
2
7
1
3
5134
3
3
1
4
634
54
47
188
3
3
2
3
2
4
2
3
170
28
140
78
3
4
2
2


wtd.
14775
6
0
26
167
1
375
0
1
73
0
0
163
668
0
2
0
1
16913
8
8
25
0
0
0
40
1
0
0
0
1
2
0
0
0
0
0
306
0
3
1
118
43
                     153

-------
TABLE 7-8 COST-EFFECTIVENESS CALCULATION FOR
   LEACHATE TREATMENT SYSTEMS  (Continued)
44. flenzo(k)f luoranthen
45. Chrysene
46. Phenol
47. Dimethylpheool
48. DCPhenol, 2,4-
49. PentaCphenol
50. TCpheool, 2,4,6-
51. Chlorophenol, 2-
52. 2-ChloroEVE
53. Bis(2-CEOxy)methane
54. Bis(CM)ether
55. Diethyl phthalate
56. Butyl benzyl ph
57. Chlordane
58. PCB-1016
59. PCB-1242
60. PCB-1254
61. Acrolein
62. TCB, 1,2,4-
63. HCB
64. HCE
65. HCButadiene
66. BCMethane
67. Fluorene
68. Acryloni tri le
69. Toxaphene
70. Bis(2-CE)ether
71. Gama-BHC
72. Alpha-BHC
Sum (organic)
Pollutant weight in

3. Antimony
'4. Arsenic
5. Cadmium
6. Chromium
7. Copper
6. Lead
9. Nickel
0. Zinc
Sum
Pollutant weight in

2.3400000 0.15
0.1458000 0.15
0.0021900 0.33
0.0026000 0.15
0.0170000 0.15
1.7560000 0.15
0.4740000 0.15
0.2150000 0.15
0.0016000 0.15
0.0000000 0.15
304.3470000 0.15
0.0000006 0.15
0.0254500 0.15
2468.9920000 0.15
7488.6080000 0.15
7488.6080000 0.15
7488.6080000 0.15
0.2840000 0.15
0.0200000 0.15
777.8000000 0.15
0.3050000 0.15
0.6130000 0.15
2.9470000 0.15
0.1120000 0.15
0.8615300 0.15
1197.8930000 0.15
0.4120000 0.15
78.9600000 0.15
18.0650000 0.15

all flow

0.0036200 0.5
32.0290000 0.5
5.0900000 0.3
0.0267000 0.3
0.4670000 0.62
1.7500000 0.62
0.1140000 1
0.1190000 1

all flow

11
16
17390
2498
1240
445
3860
494
70
11
250
131
141
200
629
86767
700
487415
9748
10000
10000
30000
130000
26
4
1
10
5400
7800
	 	 	
1,035,000
35,500,000

396
15379
6623
1067
835
993
1202
25848
52,000
1,800,000
	
2
2
5739
375
186
67
579
74
11
2
38
20
21
30
94
13015
105
73112
1462
1500
1500
4500
19500
4
1
0
2
810
1170
180,000
6,200,000

198
7690
1987
320
518
616
1202
25848
38,000
1,300,000
	
4
0
13
1
3
117
274
16
0
0
11413
0
1
74070
706550
97464608
786304
20764
29
1166700
458
2759
57467
0
1
180
1
63958
21136
-
	
100,492,000
3,451,600,000

1
246287
10113
9
242
1077
137
3076
261,000
9,000,000
— ===-===-==-==
0.7
na
na
na
na
na
na
na
na
na
0.7
na
na
na
na
na
na
0.7
0.7
0.7
0.7
0.9
0.9
0.7
0.7
na
na
na
na



0
0.47
0
0.66
0.32
0
0.36
0


=======
0
2
5739
375
186
67
579
74
11
2
11
20
21
30
94
13015
105
21934
439
450
450
450
1950
1
0
0
2
810
1170
62,000
2,100,000 3

198
4075
1987
109
352
616
769
25848
34,000
1,200,000
==============
1
0
13
1
3
117
274
16
0
0
3424
0
1
74070
706550
97464608
786304
6229
9
350010
137
276
5747
0
0
180
1
63958
21136
99,517,000
418,200,000

1
130532
10113
3
164
1077
88
3076
145,000
5,000,000
==========*»=
                     154

-------
                       TABLE  7-8  COST-EFFECTIVENESS  CALCULATION  FOR
                           LEACHATE  TREATMENT  SYSTEMS  (Continued)
Pollutant weight (organic and inorganic  37,300,000    7,500,000  3,460,600,000           3,300,000  3,423,200,000
Incremental  removal (PE) for 528 plants                                                          37,400,000
Annualized costs for all plants                                                                  286,400,000
CE ($/PE)                                                                                           7.66
  9 each plant: investment ($)                                     806,000
              land costs (20% of abov (20% of above) ($)            161,200
              O&M cost ($/y)                                     286,000
              monitoring cost ($/y)                                 5,000
              annualized cost for each plant ($/y)                  542,472
CE ($/PE) without modified air stripping & aerated equalization                                          71.60

Data  sources:  raw waste cone.(Table 5-8 & 5-9), performance (Table 6-5  with Lucas1
             modification of air stripping & aerated equalization), na = not analysed
*  Allow for 365 days per year of  leachate collection.
                                                       155

-------
                   TABLE 7-9 COST EFFECTIVENESS CALCULATION  FOR
                               AQUEOUS  TREATMENT SYSTEMS
Number of plants (N)
Uastewater flow (gpd) a each plant (q)
Number of days/year in operation (d)
Annual flow (tngy) for all plants  N x q x d
  602
45,500
  260
 7.122



No. Pollutant Name
1 CH2CL2 (HETH)
2 OCB, 1,2-
3 TCA, 1,1,1-
4 TCE
5 Chloroform
6 Chlorobenz.
7 OCA, 1,2-
8 DCA, 1,1-
9 TetraCE
10 T,-1,2-DCE
11 CCU
12 ICA, 1,1,2-
13 Chloronapthalene
H TetraCA, 1,1,2,2-
15 Toluene
16 Napthalene
17 Benzene
18 Isophorone
19 Di-n-butytphthalate
20 Bis(2-eh> phthalate
21 Phenol
22 Butyl benzyl ph
23 HCB
24 HCE
25 HCButadiene
26 Fluorene
27 Bis(2-CE)ether
28 Mitrophenol,2-
29 Diphenythydrzn,1,2-
30 Dini trotoluene,2,4-
Sum (organic)
Annual loading in all

Toxic
weighting
factor
2.9470000
0.0170000
0.0003000
0.2070000
2.9520000
0.0115000
0.5960000
0.0005600
0.7070000
0.0005000
1.4000000
0.9340000
0.3500000
3.2940000
0.0004000
0.0090300
0.8480000
0.0000100
0.0001650
2.1866700
0.0021900
0.0254500
777.8000000
0.3050000
0.6130000
0.1120000
0.4120000
0.0017000
1.0000000
0.0615000

flow

Raw wastewater
concentration

Cppb)
4966
34
1139
333
125
94
62
98
279
29
54
29
3519
13635
6110
75
2241
501
220
129
2208
165
11
41
157
13
286
66
19
57
	
	
37,000
2,198,000 4,


wtd.
(Pf*)
14635
1
0
69
369
1
37
0
197
0
76
27
1232
44914
2
1
1900
0
0
282
5
4
8556
13
96
1
118
0
19
4
,
	
73,000
336,000
	

aqueous

treatment

system
effluent cone.
Removal
0.39
na
0.41
0.26
0.16
na
0.00
0.29
0.21
0.03
na
0.08
0.46
0.49
0.41
0.22
0.31
na
0.26
0.42
0.56
0.44
na
na
na
0.16
na
0
0
na

1
(ppb)
3029
34
672
246
105
94
62
70
220
28
54
27
1900
6954
3605
59
1546
501
163
75
972
92
11
41
157
11
286



21,000
,247,000
wtd.
8927
1
0
51
310
1
37
0
156
0
76
25
665
22906
1
1
1311
0
0
164
2
2
8556
13
96
1
118



43,000
2,554,000

                                              156

-------
                      TABLE  7-9  COST  EFFECTIVENESS  CALCULATION FOR
                           AQUEOUS  TREATMENT SYSTEMS  (Continued)
31 Antimony
32 Arsenic
33 Cadmium
34 Chromium
35 Copper
36 Lead
37 Nickel
38 Zinc
39 Si Iver
40 Mercury
41 Selenium
Sum (inorganic)
Annual loading in all
0.0036200
32.0290000
5.0900000
0.0267000
0.4670000
1.7500000
0.1140000
0.1190000
46.6670000
505.0260000
0.1600000

flow
4868
248
29582
798252
268609
40665
1306957
589130
177
25
685
3,039,000
180,500,000
18
7943
150572
21313
125440
71164
148993
70106
8260
12626
110
617,000
36,646,000
0.82
na
0.88
0.83
0.93
0.91
0.53
0.93
na
0.85
na


876
248
3550
135703
18803
3660
614270
41239
177
4
685
819,000
48,644,000
3
7943
18069
3623
8781
6405
70027
4907
8260
1894
110
130,000
7,721,000
Annual loading (organic and  inorganic) 182,698,000    40,982,000

Incremental  removal  (PE) for 602 plants
Annualized costs for all plants
CE ($/PE)
  3 each plant: investment ($)
              land costs (20% of  above)  ($)
              O&M  cost ($/y)
              monitoring cost ($/y)
              annualized cost for each plant ($/y)
        49,891,000    10,275,000

                    30,707,000
                   342,900,000
                        11.17
767,002
153,400
325,310
  5,000
569,615
Data sources: raw waste cone.(Tables 5-16 & 5-17), performance (Table 6-11).  na   not analysed.
                                                     157

-------
7 . 5  SUMMARY


          Treatment  costs  were  developed  based  on  treatment
          technologies that  correspond  to  the  common  type  of
          facilities operating in the HWT industry.  Cost estimates
          developed for each subcategory were:


                                     Operating Costs,   Annualized
Subcateaorv           Investment.  $  	$/vr	   Cost,  $/yr

Leachate Treatment        806,000         286,000           542,500
Scrubber Wastewater     1,501,000         381,000           854,300
Aqueous Treaters          767,000         325,000           569,600


          Leachate  treatment  could  increase municipal  landfill
          tipping  fees.

          Implementation  of  the  model  wastewater   treatment
          technologies would  result  in a  net  decrease in  air
          emissions and increases  in  the amount of solid  wastes
          generated and energy consumed.  Air emissions potentially
          could be  reduced by  39.6 million pounds of  volatile
          pollutants per year.   The  amount  of additional  sludge
          generated could be as high  as 380,000 metric  tons  per
          year.   The  amount of increased   energy consumed as  a
          result of  possible regulations  could total 91,000 barrels
          of No.  2  fuel per year.  These  conservative estimates
          assumed that no  treatment is currently  in place.

          The cost of implementing the model technologies is modest
          compared to average revenues for the HWT industry.   The
          average incinerator would have to  increase  revenues by
          4.7   percent to cover control  costs.    A  municipal
          landfill  and  hazardous  waste  landfill  would  increase
          tipping fees by  35.5  and 3.8 percent,  respectively.   An
          aqueous treater  would be required  to increase revenues
          by 3.0 percent to cover  control costs.
                                    158

-------
                  8.0  ENVIRONMENTAL ASSESSMENT


     The purpose of this chapter is to evaluate the environmental
impact of  direct  and indirect discharges  of  wastewater from the
hazardous  waste  treatment industry  at raw and  treated effluent
levels.  Evaluations are on a subcategory basis for the three major
subgroups  comprising   the   HWT   industry:    landfill  leachate
treatment, scrubber wastewater, and aqueous waste.

     The evaluations for  subcategories are in two parts:   direct
discharge and indirect discharge assessments.  The direct discharge
analyses  use  average  effluent   concentrations   and  plant  flow
information to provide a criteria  comparison with  effluent levels,
and an estimation of stream dilution required so  as not to exceed
these  instream  criteria.    Total  pollutant  loadings  are  also
calculated for comparison  to other industries (primary and secondary
[304(m)]).  The second part of these evaluations examine the effects
of HWT indirect discharges on publicly-owned treatment works (POTWs)
and the  environment.   These assessments  evaluate three potential
impacts:    (1)    inhibition  of   POTW treatment processes;  (2)
contamination  of sludge  (thereby  limiting its use);  and (3)  plant
indirect discharge effects on surface waters.  Additionally,  total
pollutant loadings to POTWs are estimated.


8.1  METHODOLOGY

     The potential environmental impact associated with the direct
and  indirect  discharge of  wastewater from  the  hazardous  waste
treatment industry was evaluated on a  subcategory-wide basis using
raw and treated mean effluent concentrations,  the  number of plants,
and  average  plant  flows  provided by the  Industrial  Technology
Division  (ITD).     Both direct  and  indirect discharge  analyses
evaluated  priority and  nonconventional  pollutants.    The  direct
analyses employed a  critical stream dilution/required stream flow
model; the indirect  analyses used a POTW model to predict effects
due to discharge  into POTWs and, ultimately, into receiving streams.
These  evaluations  provide a general  indication   of the  extent to
which the receiving streams and POTWs  could be affected by raw and
treated wastewater discharges from this industry.


8.1.1  Direct  Discharge Analysis

     The direct discharge analyses by  subcategory, at both raw and
treated discharge levels,  included:   (1)  a comparison of effluent
concentrations   to   acute   criteria/toxicity  levels;   (2)   the
calculation of ratios of detected effluent concentrations to chronic
aquatic life, human health (water & organisms), and drinking water
criteria/standards/toxicity  levels;   (3)   the  calculation  of   a
required    stream    flow   using    the    largest    ratio    of

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concentration/criteria (critical stream dilution factor)  and average
plant  flow,  indicating  the  stream  flow required  to  dilute the
effluent  concentrations   to  a   level  equal   to  the  lowest
criteria/toxicity  level   (i.e.,  chronic, human  health,  drinking
water); and  (4)  the  calculation  of total pollutant  loadings to
receiving waters for  pollutants  evaluated  in  the model  (i.e.,
pollutants that had criteria for comparison).

8.1.2  Indirect Discharge Analysis

    The indirect discharge  analyses  step of both raw  and treated
discharges,  through the use of a POTW/water quality model, included:
(1)  the  determination of potential  inhibition of  POTW treatment
process  (determined by  comparing calculated  influent pollutant
levels with  available inhibition  levels);  (2)  an  evaluation of
potential contamination of POTW sludge and thereby limiting its use
(determined through comparison  of expected pollutant concentrations
in   POTW  sludge  with   sludge  contamination   levels);  (3)   the
determination of effects  of the resultant POTW discharge on surface
waters (determined  through comparison of calculated POTW effluent
concentrations with acute water quality criteria/toxicity levels for
aquatic  life,  and  calculated  instream  concentrations under low
stream flow conditions with chronic aquatic life, human health, and
drinking  water  criteria/standards/toxicity  levels; and   (4)  the
calculation of loadings of pollutants with  criteria to POTWs.

     Receiving stream characteristics and typical POTW  flows used
in  the indirect analyses were obtained from  EPA's IFD  and  GAGE
files.    These  characteristics  were  based on  the median  POTW
receiving industrial discharges (1 MGD)  and its corresponding median
low  (7Q10) stream flow (12 MGD).


8.2  RESULTS OF ENVIRONMENTAL ASSESSMENT

8.2.1  Landfill Leachate Subcategory

     Landfill leachate treatment facilities provide collection and
treatment of aqueous discharge  from on-site, commercial, municipal,
private,  hazardous,  industrial, and/or Subtitle D landfills.  These
discharges can  include leachate  collected  at  the  bottom  of the
landfill and any  groundwater removed from the water table.  Detailed
results are compiled in Appendix E.

8.2.1.1  Direct Dischargers

     Raw—The projected water quality impacts  from untreated  (raw)
wastewater discharges from landfill leachate treaters is significant
for all sizes of receiving streams.   The most severe  impact is from
PCB-1242,  which would require  a  stream  flow of roughly 33,000,000
million gallons per day (over 100 times greater  than  the  flow of the
Mississippi  River   at  New  Orleans)  to  reduce  the raw  effluent

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concentration to a level less than EPA's human health criterion for
carcinogenicity  protection  (risk  level  of  10"6) .    Of the  149
pollutants with human health and/or aquatic life criteria/toxicity
levels, 111 are discharged at levels greater than these levels:

          70 pollutants  (including 41 carcinogens)  have projected
          human health impacts for streams with  flows of 33,000,000
          MGD and less.

          39 pollutants  have projected short-term (acute)  aquatic
          life  impacts  in mixing  zones of  receiving  streams with
          exceedance factors ranging from 1 to 43,000.

   4* •    87 pollutants have projected  long-term  (chronic)  aquatic
          life  impacts  for streams with  flows  of 186,000  MGD and
          less.

          3-2 pollutants have projected  drinking water impacts from
          streams with less than  59 MGD flow.

     Treated—The current level  of treatment for wastewaters from
the landfill leachate subcategory reduces  the total toxic pollutant
loading from  109,000 to  70,700  Ib/day (35  percent).    Of  the 149
pollutants with criteria, 107 exceed at least one  of the four types
of criteria/toxicity levels evaluated:

          65 pollutants  (including 41 carcinogens)  have projected
          human health impacts for streams with  flows of 28,700,000
          MGD and less.
   *
  -^ •    35 pollutants  have projected short-term (acute)  aquatic
          life  impacts  in mixing  zones of  receiving  streams with
          exceedance factors ranging from 1 to 38,000.

          76 pollutants have projected  long-term  (chronic)  aquatic
          life  impacts  for streams with  flows  of 162,000  MGD and
          less.

          31 pollutants have projected  drinking water impacts from
          streams with less than  59 MGD flow.

     Pollutant Loadings to Water  (Ibs/day)

      Loading Category               Raw                Treated

    Priority organics               16,168                7,886
    Non-priority organics          54,470               47,162
    Priority inorganics              2,979                2,316
    Non-priority inorganics         35,080               13,310

    Totals                          108,697               70,674
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    The following is a narrative comparison of the direct landfill
leachate subcategory priority pollutant loadings to other regulated
industries:

    Priority  Orcranics—The  raw loading of over  16,000 Ibs/day is
comparable to the  raw  loading of the  petroleum  refining industry
(the  fourth  largest of  the BAT industries).   The  loading under
existing  treatment  (7,886  Ibs/day)  is  greater  than  all  of the
primary industrial loadings combined at BAT.

    Priority  Inorganics—The  raw  loading  of  2,979  Ibs/day  is
comparable to the aluminum forming raw  loading (ranked  in the lower
half of the BAT industries).  The treated loading of 2,316 Ibs/day
is comparable to the iron and steel  industrial loading at BAT (the
fifth largest of the BAT industries).

8.2.1.2  Indirect Dischargers

    Indirect   dischargers   were  evaluated  based   on  projected
discharges to a model  1  MGD POTW and  a  12  MGD  receiving stream
(representing median sizes for POTWs receiving indirect discharges
from industrial sources).
       v—The  water  quality impacts of untreated  (raw)  wastewater
to  POTWs  from this  subcategory are  less  significant  than those
projected for  direct  dischargers.   Only 34 of  the  149  pollutants
with criteria/toxicity levels exceeded one or more of these levels:

        24  pollutants  (including  21  carcinogens)   have projected
        human  health  impacts  with exceedance  factors  of  up to
        2,700,000.

        9 pollutants have projected short-term (acute) aquatic  life
        impacts in mixing zones of receiving streams with exceedance
        factors ranging  from 1 to  1,300.

        14  pollutants have projected  long-term (chronic)  aquatic
        life impacts  with  exceedance  factors of up to 15,000.

        4 pollutants are projected to  cause drinking water impacts.

        4 inorganic  pollutants are projected   to cause potential
        inhibition of wastewater treatment process operations.

        1 inorganic pollutant is projected to cause potential sludge
        contamination.

    Treated—Current treatment of  indirect discharges reduces toxic
pollutant  loadings by 35 percent (from 223,000  to 145,000 Ib/day)
Exceedances  of water quality criteria  and toxicity levels are  also
reduced;  however,  not significantly:

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        18  pollutants  (including  17 carcinogens)  have projected
        human  health  impacts  with  exceedance factors  of up  to
        2,600,000.

        7 pollutants have projected short-term (acute) aquatic life
        impacts in mixing zones of receiving streams with exceedance
        factors ranging from 1 to  1,130.

        10  pollutants have projected long-term  (chronic)  aquatic
        life impacts  with exceedance factors  of up to 13,000.

        2 pollutants are projected to cause drinking water impacts.

        3  inorganic pollutants  are projected to cause potential
        inhibition  of wastewater treatment process operations.

        1 inorganic pollutant is  projected to cause potential sludge
        contamination.

    An additional  84  pollutants were detected in discharges  from
this subcategory,  but do  not have any toxic levels or criteria for
comparison.

    Pollutant Loadings  to Water  (Ibs/day)


    Loading Category                 Raw               Treated

    Priority organics                33,179              16,181
    Non-priority organics          111,773              96,779
    Priority inorganics             6,133               4,753
    Non-priority inorganics          71,984              27,311
    Totals
223,069             145,024
    A  narrative  comparison  of  the  indirect  landfill  leachate
priority pollutant  loadings to regulated  industries  is presented
below:

    Priority Organics—A raw loading of 33,179 Ibs/day is slightly
less than  that of the metal  finishing (the third  largest  of the
regulated  industries  indirect  loadings).   At  treated levels, the
loading of 16,181 Ibs/day is comparable to the PSES loading of the
pulp and paper  industry (the largest indirect loading from regulated
industrial categories).

    Priority Inorganics—The raw  loading of  6,133 Ibs/day is  about
a third larger  than that discharged by the aluminum forming industry
(ranked in the  lower half in terms of raw loadings).  Under existing
treatment, the loading of 4,753 Ibs/day is greater  than any of the

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primary industrial PSES loadings, with  the  exception of the metal
finishing industry-

8.2.2  Scrubber Wastewater Subcateqory

    Incinerator scrubber wastewater treatment facilities are limited
to those facilities  treating  only  incinerator scrubber wastewater
or on-site generators of incinerator scrubber wastewaters that are
combined with other  wastewater for treatment.  Detailed results are
presented in Appendix F.

8.2.2.1  Direct Dischargers
    	I—Projected water quality impacts from direct discharges of
raw scrubber wastewater are significant from streams with flows less
than 44,000  MGD.   Of the 29 pollutants with  criteria or toxicity
levels, 27 of these exceed these levels  (2 additional pollutants do
not have criteria/toxicity levels):

         13 pollutants (including 5 carcinogens) have projected human
         health  impacts  for streams with  flows of 44,000  MGD and
         less.

         9 pollutants have projected  short-term (acute) aquatic life
         impacts in mixing zones of receiving streams with exceedance
         factors ranging  from 1 to 1,325.

         20  pollutants have projected long-term  (chronic)  aquatic
         life impacts  for streams with flows of 616 MGD and less.

         11  pollutants have  projected drinking water impacts from
         streams with  less than 51 MGD flow.

    Treated—After treatment, loadings  from direct  discharges are
reduced  significantly from  45,700  to  1,040 Ib/day (almost  98
percent). While the total number of  pollutants that exceed at least
one type  of criterion/toxicity level  is reduced only moderately
(from 27  to  19) , the magnitudes of these exceedances are reduced by
several orders of magnitude:

         12 pollutants (including 5 carcinogens) have projected human
        health impacts for streams with flows of 440 MGD and less.

         5 pollutants have projected  short-term (acute) aquatic life
         impacts in mixing zones of receiving streams with exceedance
         factors ranging  from 2 to 16.

         12  pollutants have projected" long-term  (chronic)  aquatic
         life impacts  for streams with flows of 16 MGD and  less.

         5 pollutants  have projected  drinking water  impacts from
         streams with  less than 1.1 MGD  flow.

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    Pollutant Loadings to Water  (Ibs/day)


     Loading Category                   Raw              Treated
Priority organics
Non-priority organics
Priority inorganics
Non-priority inorganics
151
439
20,539
24,547
14
50
254
722
    Totals                          45,676                1,040


    The  following  is  a  narrative  comparison of  the  scrubber
wastewater treatment priority pollutant loadings to other regulated
industries.

    Priority Organics—The raw loading of 151  Ibs/day is comparable
to the  raw loading of  the plastics molding  and  forming industry
(ranked in the lower third of the primary industries).  The loading
under existing treatment  (14  Ibs/day)  is comparable to the copper
forming industrial loading at BAT (which is also ranked  in the lower
third).

    Priority  Inorganics—The  raw  loading  of  20,539  Ibs/day  is
comparable to the  raw  loading of the inorganic chemicals industry
(ranked  in the  upper  half  of  the  primary  industries) ,  and  the
treated  loading  of 254   Ibs/day  is  almost  twice that  of  the
electrical components industry at BAT  (ranked in the middle of the
primary industries).

8.2.2.2  Indirect  Dischargers

    Indirect  dischargers  were  evaluated   based   on  projected
discharges to  a model  1  MGD POTW  and a 12  MGD  receiving stream
(representing median sizes for POTWs receiving  indirect discharges
from industrial  sources).

    Raw—The water quality impacts of untreated (raw) wastewater to
POTWs from this  subcategory are much  less  significant than those
projected for direct dischargers. Only 11 of the 29  pollutants with
criteria/toxicity  levels  exceeded one  or more of these levels:

         3 pollutants (including  2 carcinogens) have  projected human
         health impacts with  exceedance factors of up to  2,230.

         6 pollutants have projected short-term (acute)  aquatic life
         impacts  in mixing zones of receiving streams with  exceedance
         factors  ranging from 1 to 27.

         7 pollutants have projected long-term  (chronic)  aquatic life
         impacts  with exceedance factors of up to 18.

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        1 pollutant is projected to cause drinking water impacts.

        4  inorganic  pollutants are projected  to cause  potential
        inhibition of wastewater treatment process operations.

        6  inorganic  pollutants are projected  to cause  potential
        sludge contamination.

    Treated—Current treatment of indirect discharges reduces toxic
pollutant loadings by almost  98 percent (from 9,000 to 205 Ib/day).
Exceedances of water quality  criteria  and toxicity levels are also
significantly reduced:

        2 pollutants (both carcinogens) have projected human health
        impacts with exceedance factors of 2 and 22.

        No pollutants are projected to cause short-term (acute) or
        long-term  (chronic) aquatic life or drinking water impacts
        in receiving streams.

        1  inorganic  pollutant is  projected to  cause  potential
        inhibition of wastewater treatment process operations.

        1 inorganic pollutant is projected to cause potential sludge
        contamination.

    Pollutant Loadings to Water (Ibs/day)


    Loading Category                   Raw              Treated

    Priority organics                   30                  3
    Non-priority organics               87                 10
    Priority inorganics              4,048                 50
    Non-priority inorganics          4,837                142

    Totals                           9,002                205

    A  narrative  comparison  of  the  indirect  priority  pollutant
loading of the scrubber wastewater treatment  subcategory with other
industries is presented below:

    Priority Organics—A raw loading of 30  Ibs/day is less than any
of the primary raw organic industrial  loadings  with the exception
of  the  aluminum  forming industry   (3  Ibs/day)  and  industries
discharging essentially  no  organics.   The  treated loading  of 3
Ibs/day is comparable to  the copper forming industry at PSES  (the
lowest of the primary industries with non-zero levels).

    Priority  Inorganics—The  raw  loading  of  4,048  Ibs/day   is
slightly less than that discharged by the aluminum forming industry

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(ranked  in  the middle  in  terms of  inorganic loadings).   Under
existing treatment, the loading of 50 Ibs/day is comparable to the
PSES loading of the  foundries  industry  (also ranked in the middle
for inorganic loads at PSES).


8.2.3  Aqueous Hazardous Waste Subcategory

    Aqueous hazardous waste treatment facilities provide physical,
chemical, and/or biological treatment of hazardous and nonhazardous
wastewaters, including leachate from on-site  and off-site landfills
and process  wastewaters  from  on-site and  off-site manufacturing
operations.    Whereas  leachate  treatment  facilities  handle  only
wastewater generated on-site, commercial aqueous treaters handle a
variety of wastewaters, including leachates.  Detailed results are
presented in Appendix F.

8.2.3.1  Direct Dischargers

    Raw—Aqueous hazardous waste treatment  facilities can adversely
impact receiving streams  with  flows  less than 5,130 MGD, based on
the  evaluation of untreated,  or  raw,  discharges.    Of  the  77
pollutants with human health and/or aquatic life criteria/toxicity
levels  that  have  been  detected  in the  wastewater  from  this
subcategory, 55 are discharged at levels that cause exceedances (6
additional  detected pollutants  have  no  applicable   criteria  or
toxicity levels):

         31  pollutants  (including  21 carcinogens)  have projected
         human health impacts for streams with flows of 5,130 MGD and
         less.

         17 pollutants have projected short-term (acute)  aquatic life
         impacts in mixing zones of receiving streams with exceedance
         factors ranging from  1 to  15,000.

         36  pollutants  have projected long-term  (chronic)  aquatic
         life impacts for  streams with flows  of 1,224 MGD and less.

         22  pollutants  have projected drinking water impacts from
         streams with less than 726 MGD flow.

    Treated—After treatment,  loadings  from direct discharges are
reduced by almost  78 percent (from 198,000 to 44,400 Ib/day).  While
the total number  of pollutants  that exceed at least  one  type of
criteria/toxicity level is  similar to untreated discharges (53 and
55, respectively), the magnitudes of these exceedances are reduced
by more than 50 percent:

         28  pollutants  (including  21 carcinogens)  have projected
         human health impacts for streams with flows of 2,090 MGD and
         less.

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        16 pollutants have projected short-term (acute) aquatic life
        impacts in mixing zones of receiving streams with exceedance
        factors ranging from 1 to 1,044.

        33 pollutants  have  projected long-term  (chronic)  aquatic
        life impacts for streams with flows of 175 MGD and less.

        21 pollutants  have  projected drinking water  impacts from
        streams with less than 124 MGD flow.

    Pollutant Loadings to Water (Ibs/day)

     Loading Category                   Raw              Treated
Priority organics
Non-priority organics
Priority inorganics
Non-priority inorganics
1,283
9,635
99,880
87,181
737
2,951
26,994
13,716
    Totals                         197,979                44,398


    The following  is  a  narrative comparison of the  aqueous waste
treatment priority  pollutant loadings to other regulated industries.

    Priority Organics—The raw loading of 1,283  Ibs/day is 1.5 times
the loading of the copper forming industry and 60 percent  of the
foundries loading under  raw discharge conditions (ranked eighth and
seventh,  respectively).   The treated  loading of  737  Ibs/day is
comparable to  the  BAT  loading  of  the  textiles industry   (ranked
third).

    Priority  Inorganics—The raw  loading  of  99,880   Ibs/day  is
approaching the raw industrial loading of the organics/P&SF industry
(ranked fifth at 125,000  Ibs/day).   The treated  loading of 26,994
Ibs/day is greater  than any reported primary BAT industrial loading,
and slightly  greater than the  total inorganic  loading of POTWs
discharging to surface waters nationwide.

8.2.3.2  Indirect Dischargers

    Indirect   dischargers were  evaluated  based   on   projected
discharges to  a  model 1 MGD POTW  and  a 12 MGD  receiving   streams
(representing median sizes for POTWs receiving indirect discharges
from industrial sources).

    Raw—The water quality impacts of Untreated (raw) wastewater to
POTWs  from  this  subcategory   are   less  significant   than those
projected for direct dischargers.  Only 22  of the 77 pollutants with
criteria/toxicity levels exceeded one or more of these  levels:


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         12  pollutants  (including  10 carcinogens)  have projected
         human  health  impacts with  exceedance  factors of up to 260.

         7 pollutants have projected short-term (acute)  aquatic life
         impacts in mixing zones of receiving streams with exceedance
         factors ranging from 1 to  134.

         10  pollutants have projected long-term (chronic)  aquatic
         life impacts  with exceedance factors  of up to  39.

         4 pollutants are projected to cause drinking water impacts.

         6  inorganic pollutants  are projected  to  cause  potential
         inhibition  of wastewater treatment process operations.

         6  inorganic pollutants  are projected  to  cause  potential
         sludge contamination.

    Treated—Current treatment of indirect discharges reduces toxic
pollutant loadings by almost 78 percent (from 1,172,000 to 263,000
Ib/day).   Exceedances of water  quality criteria  and toxicity levels
are also reduced;  however, not as significantly:

         11  pollutants  (including  10 carcinogens)   have  projected
         human  health  impacts with exceedance factors of up to 116.

         5 pollutants have projected short-term (acute) aquatic life
         impacts in mixing zones of receiving streams with exceedance
         factors ranging from 1 to  16.

         5 pollutants have projected long-term (chronic) aquatic life
         impacts with  exceedance  factors of up to 9.

    •     2 pollutants are projected to cause drinking water impacts.

    •     5  inorganic pollutants  are  projected to  cause  potential
         inhibition of wastewater treatment process operations.

    •     5  inorganic pollutants  are  projected to  cause  potential
         sludge contamination.

    Pollutant Loadings to Water  (Ibs/day)


    Loading Category                   Raw              Treated
Priority organics
Non-priority organics
Priority inorganics
Non-priority inorganics
7,593
57,035
591,246
516,073
4,361
17,469
159,791
81,193
    Totals                       1,171,947            262,814

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    A narrative comparison of indirect priority pollutant
from the aqueous waste treatment subcategory to primary
is presented below.

    Priority Orcranics—A raw loading of 7,593 Ibs/day is about 1.5
times that of the textiles  industry at raw, and about 45 percent ot
the raw pulp and paper  industrial loading (ranked fifth and rourtn,
respectively) .  The treated loading of 4,361  Ibs/day is greater than
any reported raw primary industrial PSES  loadings with the exception
of the pulp and paper industry -

    Priority  Inorganics—The  raw  loading  of  591,246 Ibs/day  is
comparable  to the raw loading  of  the  metal  finishing  industry
(ranked second).  The treated loading of 159,791 Ibs/day is greater
than all primary PSES loadings combined.


8.3  NONWATER QUALITY ENVIRONMENTAL ASPECTS

    The elimination or  reduction of one form  of pollution may create
or  aggravate  other  environmental problems.   Therefore,  Sections
304 (b)  and  306  of  the Clean  Water  Act (CWA)  require the  U.S.
Environmental Protection Agency (EPA)  to consider nonwater quality
environmental aspects of certain regulations.  In  compliance with
these  provisions, EPA has  considered  the  effect  of  possible
regulations on  air pollution,  solid waste generation,  and energy
consumption. The nonwater  quality environmental aspects associated
with possible regulation are described below.

8.3.1  Air Pollution

    Implementation of  the  model  wastewater  treatment technologies
would result  in an  overall reduction in air emissions.   This  is
largely due  to the incorporation of effective air pollution controls
for  the model  leachate  treatment  technologies.    For  example,
existing leachate treaters are known to operate wastewater treatment
units, such  as aerated equalization basins and aerated lagoons, that
are open  to the  atmosphere.   The  model technology  requires air
stripping in a covered unit with venting to  existing air pollution
control devices.  Since the air stripper is  located at the head of
the treatment train,  the possibility  of significant air emissions
from downstream units  is  minimized.   The  net  effect would  be a
reduction from current air emissions of 39.6 million pounds to 1.2
million pounds per year if  the assumption is made that no treatment
is in-place prior to  implementation of a possible regulation.

    The  technologies  recommended  for  the   aqueous and  scrubber
subcategories are similar to those  technologies  currently used by
the hazardous waste  treatment  (HWT) industry.   The  Development
Document  for Effluent  Limitations  and Standards  for the  Metal
Finishing  Point  Source  Category  associated  no significant air

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emissions .with  the unit operations recommended  here as model HWT
technologies.  However, the EPA Office of Air Quality Planning and
Standards (OAQPS) is developing regulations to require the enclosing
of  hazardous waste  storage  and  treatment  units.    Preliminary
information developed by OAQPS suggests that no significant changes
in air emissions would result from operation of aqueous and scrubber
subcategory technologies.

8.3.2  Solid Waste

    EPA considered the effect possible regulations would have on the
production of solid waste, including hazardous waste defined under
Section 3001 of the Resource Conservation and Recovery Act (RCRA).
EPA estimates that the total solid waste, including hazardous waste,
resulting  from   a possible  regulation would  be significant  for
facilities that  do not have treatment  in-place.   For  example,  an
aqueous hazardous waste treater  would  generate  420  metric tons of
sludge  (total  sludge  generated,  dewatered to 20  percent solids)
annually  as  a   result  of  implementing  the  model  technology.
Similarly, a  facility in the leachate  subcategory  would generate
240 metric  tons  (includes  both  primary and biological treatment
sludges,  dewatered to 20 percent  solids)  annually.   The  model
technologies recommended for the scrubber subcategory would result
in  no  sludge  generation.    An  inventory  of   treatment  systems
currently in use by the HWT industry is not available.  However, if
the  assumption   is made  that  no  treatment  is  in-place,  then  a
possible regulation would  result in 380,000 metric  tons of sludge
generated annually.

8.3.3  Energy Recruirements

    Implementation of the model  wastewater treatment technologies
would  increase  energy consumption  over present  industry use.   For
example, a typical aqueous treater would consume 37 barrels of No.
2  fuel oil  per  year over current levels  if  no  treatment  were
in-place.   Similarly, facilities  in   the  leachate and  scrubber
subcategories would  consume  127  and 12 barrels  of  No.  2  fuel oil
per year,  respectively. An inventory of treatment systems currently
in  use by the  HWT industry  is  not available.   However,  if the
assumption is made that no treatment is in-place, then a possible
regulation  would  result  in  an  increased  consumption  of  91,000
barrels of No. 2  fuel  per year.
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                         9.  REFERENCES


 1.  U.S.  EPA.  1987.  "Summary Report on RCRA  Permit Activities
     for January 1987."  OSW.   February 17,  1987.

 2.  McCoy  and  Associates.     1985.     "The  Hazardous   Waste
     Consultant."  Vol. 3,  No.  2.   March/April 1985.

 3.  Environmental   Information  Ltd.,   1986.     Industrial—jnd
     Hazardous Waste Management Firms 1987.  Minneapolis, Minesota.

 4.  U.S.  EPA.  1986.  "Census of  State and Territorial Subtitle
     D Nonhazard ous  Waste  Programs," EPA/530-SW-86-039.  October
     1986.

 5.  U.S.  EPA.  1986.  State Subtitle D Program Questionnaire Data.

 6.  Bramlett, J. ,  C.  Furman,  A.  Johnson,  and H. Nelson.   1985.
     "Composition of  Leachates  from Actual Hazardous Waste Sites."
     September 30,  1985.

 7.  McGinley,  P.M.,   and  P-   Kmet.      1984.      "Formation,
     Characteristics, Treat ment,  and  Disposal of Leachate from
     Municipal  Solid  Waste Landfills." Wisconsin Department  of
     Natural Resources.  Special  Report.   August 1,  1984.

 8.  U.S.  EPA.   1985.   "Directory of Commercial  Hazardous Waste
     Treatment  and  Recycling   Facilities,"   EPA/530-SW-85-019.
     December 1985.

 9.  Keitz,  E. ,  et  al.  1984. "Profile of Existing Hazardous Waste
     Incineration  Facilities   and  Manufacturers  in  the  United
     States." EPA-600/2-84-052.  Mitre Corporation.  February 1984.

10.  U.S.  EPA.   1986.   National  Screening Survey of  Hazardous
     Waste-Wastewater Treatment Facilities Data.

11.  U.S.  EPA.   1986.   "1985 Survey  of Selected  Firms  in  the
     Commercial  Hazardous   Waste   Management  Industry."    Final
     Report, Office of Policy Analysis.  November 6,  1986.

12.  U.S.  EPA.  1986.  "Test Methods for Evaluating Solid Waste."
     Third Edition, SW-846. November 1986.

13.  U.S.  EPA.  1984.   "Guidelines Establishing Test Procedures for
     the  Analysis  of  Pollutants  Under  the Clean  Water  Act."
     Federal Register.  Vol. 49, No. 20*9.   October 26,  1984.

14.  U.S.  EPA.   1986.   "Report  to Congress on the Discharge of
     Hazardous  Waste   to   Publicly  Owned  Treatment  Works "
     EPA/530-SW-86-004.  February 1986.

                               172

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                      REFERENCES (Continued)


15.  McNabb, G.D., J.R.  Payne, W. D. Ellis, J.A.  Bramlett,  and P.C.
     Harkins.  1987.    "Composition  of  Leachates  from  Actual
     Hazardous Waste Sites." Presented  at  13th  Annual Research
     Symposium,  Land Disposal,  Remedial  Action Incineration and
     Treatment of Hazardous Waste, Cincinnati, Ohio. May 6-8, 1987.

16.  U.S.  EPA.    1986.    "Subtitle  D  Study  Phase  I  Report."
     EPA/530-SW-86-054, OSW.  October 1986.

17.  U.S. EPA.  1986.  "Evaluation of SCA Chemical Services Model
     City, N.Y." EPA-330/2-86-002, HWGWTF.  April 1986.

18.  U.S.  EPA.   1986.    "Evaluation  of  Wayne  Disposal,  Inc.,
     Belleville, MI." EPA-330/2-86-008, HWGWTF.  July  1986.

19.  U.S.  EPA.   1986.    "Evaluation  of GSX  Services of  South
     Carolina,   Inc.   Genstar   Corporation,   Pinewood,   SC."
     EPA-330/2-86-009, HWGWTF.  August 1986.

20.  U.S. EPA.  1986.  "Evaluation of Fondessy Enterprises, Inc.,
     Oregon, OH."  HWGWTF, EPA-700/8-87-007.  December 1986.

21.  U.S.  EPA.    1986.    "Evaluation of Rollins  Environmental
     Services   (TX),   Inc.,    Deer   Park,   Texas."     HWGWTF,
     EPA-330/2-86-010.  July 1986.

22.  U.S. EPA.   1986.   "Evaluation of American Cyanamid,  Milton,
     FL."  HWGWTF, EPA-700/8-87-004.  November 1986.

23.  U.S. EPA.   1986.   "Onsite Engineering Report  of Treatment
     Technology Performance and Operation for Envirite Corporation,
     York, PA."  OSW. December  19, 1986.

24.  Metcalf and Eddy, Inc. 1986.  "Final Facility Test Report for
     Frontier  Chemical  Waste Process, Inc., Niagara Falls, NY."
     October 1986.

25.  U.S. EPA.    1986.    Hazardous  Waste Data  Management System
     (HWDMS) data retrieval.  OSW.  March 5, 1986.

26.  Wisconsin Department of Natural Resources.   1984.   Special
     Report, August 1, 1984.

27.  George,  J.A.    1972.   Sanitary  landfill-gas  and leachate
     control,  the  national perspective.   Office  of Solid Waste
     Management Programs,  U.S. EPA.
                               173

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                     REFERENCES  (Continued)


28.  Chian, E.S.K. and  F.B.  De Walla.  1976.   Sanitary landfill
     leachates   and   their   treatment.     Journal   ASCE   102
     (EE2):411-421.

29.  Metry, A.A.  and F.L. Cross.   1975.   Leachate  Control and
     Treatment.   Vol. 7, Environmental Monograph Series, Technomic
     Publishing Co.,  Westport,  Connecticut.

30.  Cameron,  R.D.  1978.  The effects of solid waste leachates on
     receiving waters.   Journal AWWA,  March  1978:173-176.

31.  ICF,  Inc.   1986.  "Survey of Selected Firms in the Commercial
     Hazardous  Waste Management  Industry."    Washington,  D.C.
     November 1986.

32.  U.S.   EPA,  Office  of Air  Quality Planning  and  Standards.
     Correspondence from Robert B.  Lucas to  Donald F.  Anderson.
                              174

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