PROPOSED
BEST DEMONSTRATED AND AVAILABLE TESHNOLOGY,(BDA|)
BACKGROUND DOCUMENT'
FOR WASTES FROM THE PRODUCTION'OF-
DINITROTOLUENE, TOLUENEDIAMINE,'-AND TOLUENE DIISOCYANATE
K027, K111-K116, U22-1-, U223.
U.S. Environmental Protection'Agency
Office of Solid Waste ''* '
401 M Street, S'.W.
Washington, D.C.
December 30, 1988
K027 BGD-2
1107-01.nrj.1
-------
TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION 1-1
2.0 INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industry Affected and Process Description 2—2
2.2 Waste Characterization 2—7
2.3 Determination of Waste Treatability Groups 2-10
3.0 APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3—1
3.1.1 K027, K113—K116, U221, and (J223 Treatability
Group . 3-2
3.1.2 K115 Metals 3— 4
3.1.3 Kill and K112 Treatability Group 3-5
3.2 Demonstrated Treatment Technologies 3-6
3.2.1 K027, K113—K116, U221, and U223 Treatability
Group 3-6
3.2.2 K115 Metals 3—7
3.2.3 Kill and K1i2 Treatability Group 3—8
14.0 TREATMENT PERFORMANCE DATA BASE 4-1
5.0 IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
(BDAT) 5—1
5.1 Determination of EDAT for K027, K113-K116, U221, and
U223 Nonwastewater Organics 5-2
5.1.1 Identification of BDAT 5-2
5.1.2 Evaluation of Substantial Treatment by
Incineration and Fuel Substitution 5-3
5.2 Determination of BOAT for K027, K113—K116, U221, and
U223 Wastewater Organics 5-il
5.3 Determination of BDAT for Nickel in K115 5_iLl
5.14 Summary of Proposed BDAT for the K027, K1l3—Kl l6,
U221, and 13223 Treatability Group 5-16
6.0 SELECTION OF REGULATED CONSTITUENTS 6-1
7.0 DEVELOPMENT OF BDAT TREATMENT STANDARDS 7-1
8.0 DETERMINATION OF THE BEST REGULATORY APPROACH FOR THE
Kill, K112 TREATP.BILITY GROUP 8-i
9.0 REFERENCES 9—1
APPENDIX A: CBI WASTE CHARACTERIZATION DATA
APPENDIX B: APPLICATION OF THE SECTION 5.1.2 METHODOLOGY
ON THE K027, K113—Kli6, 13221, and U223
TREATABILITY GROUP
K027 BGD-2 i
1107—01 .nrJ .2
-------
LIST OF TABLES
Table Page
2—1 FACILITIES THAT MAY GENERATE K027, Kill, K112, K113, K11 14,
K115, AND/OR K116 BY STATE AND EPA REGION 2-3
2-2 SUMMARY OF PUBLICLY AVAILABLE WASTE CHARACTERIZATION DATA
FOR WASTE CODES K027, Kill, K112, K113, K1l 1 4, K115, AND
K116 2—8
14.1 WASTE CHARACTERIZATION DATA FOR K027, Kl13—K116 4- L I
TREATMENT PERFORMANCE DATA FOR K0l5: LIQUID INJECTION
INCINERATION 4-5
4.3 TREATMENT PERFORMANCE DATA FOR K086: ROTARY KILN
INCINERATION 4-6
TREATMENT PERFORMANCE DATA FOR F024: ROTARY KILN
INCINERATION 4—7
SUMMARY OF OPERATING DATA FOR INCINERATION OF K105, K086,
F024, AND K027 4-8
TREATMENT PERFORMANCE DATA FOR K103 AND K1014: CARBON
ADSORPTION 4-9
4-7 TREATMENT PERFORMANCE DATA FOR NICKEL TRANSFERRED FROM
STABILIZATION OF F006 NONWASTEWATER 4-10
14...8 TREATMENT PERFORMANCE DATA FOR NICKEL TRANSFERRED FROM
LIME AND SULFIDE PRECIPITATION FOLLOWED BY VACUUM
FILTRATION OF K062 WASTEWATER 4-li
5-1 COMPARISON OF CONSTITUENTS IN K015, KOS6, AND FO2 1 4 THAT
ARE MORE DIFFICULT TO TREAT THAN THE CONSTITUENTS OF
CONCERN IN K027, K113—K116, U22i, AND U223 5-9
K027 BGD—2 11
1107—01 .rirj.14
-------
LIST OF FIGURES
Figure Page
2-1 FLOW DIAGRAM OF PROCESSES GENERATING THE K027 AND
K111-K116 WASTE CODES 2 14
5-1 FLOWCHART ILLUSTRATING THE PROCEDURE USED TO SHOW
SUBSTANTIAL TREATMENT BY INCINERATION OR FUEL
SUBSTITUTION 5-5
K027 BGD—2 lii
1107-01 .nrj .5
-------
1.0 INTRODUCTION
The Hazardous and Solid Waste Amendments (HSWA) Act, enacted on
November 8, 198)4, amended the Resource Conservation and Recovery Act of 1976
(RCRA). Pursuant to HSWA, Section 300 )4(g) of RCRA requires EPA to promulgate
regulations that restrict beyond specified dates the land disposal of
untreated hazardous wastes. Under Section 300)4(m) of RCRA, the Agency is
required to set “levels or methods of treatment, if any, which substantially
reduce the likelihood of migration of hazardous constituents from the waste so
that short-term and long-term threats to human health and the environment are
minimized.” As specified in the promulgated regulatory framework for imple-
menting the land disposal restriction, these “treatment standards” are based
on the performance of the best demonstrated available technologies (BDAT) for
a waste. If a waste or treatment residual, as generated or treated, meets the
BDAT treatment standards established by EPA for that waste, then the prohi-
bition on land disposal does not apply and the waste may be land disposed.
This background document provides the Agency’s rationale and techni-
cal support for the proposed treatment standards for the listed wastes identi-
fied in ) 4O CFR 261.31 as K027, K113, Kl1 4, K115, K116, U221, and U223. K027,
which is generated from the production of toluene diisocyanate (TDI), is part
of the second—third of the scheduled listed wastes to be evaluated by the
Agency for land disposal restrictions. Wastes listed as Kill, K112, K113,
K11 ) 4, K115, and K1i6, which are generated from the production of dinitro-
toluene (DNT), toluenediaxnine (TDA), or toluene diisocyanate (TDI), are “newly
K027 BGD-2 1-1
1128—01 .rnlm. 1
-------
listed” (i.e., listed after the effective date of HSWA). Treatment standards
for K113-K116 are being proposed as part of this second—thirds rulemaking.
The Agency is not proposing treatment standards for the newly listed wastes
Kill and K112 at this time. In addition, the Agency is proposing treatment
standards for soft-hammered first-third U wastes, U22l and U223. This pro-
posed regulation also addresses K027, K113—K116, U221, and U223 wastewaters
generated from RCRA corrective actions and CERCLA remedial orders (as either
contaminated ground or surface water).
In cases where EPA believes that constituents present in wastes
represented by different codes can be treated to similar concentrations using
the same technology, the Agency may combine the wastes into one treatability
group (53 FR 3l1L 5, August 17, 1988). Based on a review of waste generation,
waste management practices, and waste characterization data for the wastes,
EPA believes that these wastes comprise two waste treatability groups: (1)
the K027, K113-K116, U221, and U223 treatability group and (2) the Kill and
K112 treatability roup.
EPA may establish treatment standards either (1) as a specific
treatment technology or (2) as a performance level of treatment monitored by
measuring the concentration levels of the hazardous constituents in the waste,
treatment residual, or an extract of the waste. While EPA prefers to estab-
lish treatment standards as performance levels, this approach is not always
possible. As discussed in this background document, EPA is proposing BDAT
treatment standards for the K027, K113-K116, 1J221, and U223 treatability group
K027 BGD—2 1—2
1128—01 .rnlm.2
-------
as a specific treatment technology, incineration or fuel substitution. For
the KilS waste code, EPA also proposes to establish performance level treat-
ment standards for nickel in wastewaters and nonwastewaters since this BDP.T
List metal constituent is present at treatable concentrations in the waste and
treatment performance data are available for this constituent. The Best
Demonstrated and Available Technologies (BDAT) for treatment of nickel in
combustion residues from treatment of K115 are stabilization of K115 nonwaste-
waters (e.g. spent filter cartridges from filtering incineration scrubber
waters) and lime and sulfide precipitation followed by vacuum filtration for
K115 wastewaters. The Agency is soliciting characterization data for K115
combustion residues to verify the assumption that these wastes contain treat-
able concentrations of nickel.
The Agency’s decision to establish proposed treatment standards as a
specific treatment technology for the K027, K113—K116, 1J221, and U223 treat-
ability group (except for nickel in K115 which is being proposed at a numeri-
cal performance treatment level) Is based on the following rationale. The EPA
does not have, at this time, any treatment performance data for any of the
wastes in this treatability group. The Agency has not pursued testing of
performance for these wastes because EPA currently lacks analytical methods
that can satisfactorily analyze for toluidine, TDI, TDA, and other major
organic constituents (i.e., the constituents that would be selected for
regulation due to their presence in the untreated wastes) at high concentra-
tions in complex waste matrices. Also, the Agency has not been able to
identify any method, parameters, or indicator constituents for the hazardous
K027 BGD-2 1-3
1128-01 .rnlm.3
-------
organic constituents present in these wastes. Therefore, the Agency believes
that meaningful concentration—based BDAT treatment standards for organic
constituents comprising these wastes cannot be developed at this time.
The Agency is instead proposing treatment standards of incineration
and fuel substitution as the specific BDAT methods of treatment for K027,
K113, K1U4, K115, K116, U221, and U223 nonwastewaters and wastewaters other
than scrubber waters. In order to specify a method of treatment, EPA must
show that the technology is BDAT for those wastes. For a technology to be
considered BDAT, it must be shown to provide substantial treatment of the
constituents of concern. In the absence of treatment performance data,
substantial treatment is determined by showing that the technology provides
substantial treatment for a similar waste that is more difficult to treat than
the waste of concern. This background document presents EPA ’s documentation
that the demonstrated treatment technologies, incineration and fuel substi-
tution for nonwastewaters and carbon adsorption for wastewaters, provide
substantial treatment of hazardous constituents in the K027, K113-K116, U221,
and U223 treatability group based on a review of treatment performance data
for other wastes. However, K027, K113-K116, (J221, and U223 wastewater
residuals generated from incineration or fuel substitution will not require
treatment by carbon adsorption and will not be prohibited from land disposal
since these residuals do not require further treatment for hazardous organic
constituents. KilS wastewater residuals generated from incineration or fuel
substitution must also meet the numerical standard for nickel prior to land
disposal.
K027 BGD-2 1-Li
1128—01 .mlrn. 1 4
-------
Similarly, EPA does not have any treatment performance data for Kill
or K112, and the Agency lacks analytical methods that can satisfactorily
analyze for the major organic constituents in this treatability group. Unlike
the K027, K113-K116, U221, and U223 treatability group, the Agency cannot
presently show substantial treatment by specific treatment technologies for
this treatability group. Therefore, the Agency has decided to address these
wastes at a later date. Since these wastes were listed after the enactment of
HSWA, land disposal of’ these wastes is not subject to either the “soft hanm er”
provisions or the May 8, 1990 “hard hammer” provisions.
Section 2.0 of this document presents information on the industry
affected and waste characterization data available for K027, and K1i1-K116. A
more detailed discussion is also included for the determination of waste
treatability groups identified for the K027, Kiii—K116, U221, and U223 waste
codes. Section 3.0 presents the applicable and demonstrated treatment tech-
nologies for the treatability groups while Section 1 .0 presents treatment
performance data used in determining BDAT for the treatability groups. (As
discussed above, treatment performance data are not available for use in
determining BDPIT for the Kill and K1l2 treatability group.) Section 5.0
explains EPA’s proposed determination of BDAT for the treatability groups.
Section 6.0 discusses the selection of nickel being proposed for regulation in
K1l5 and Section 7.0 explains the calculation of the proposed treatment
standard for nickel in KilS. The rationale for addressing the Kill and K112
treatability group at a later date is discussed in Section 8.0.
K027 BGD-2 1-5
1128—01 .mlm.5
-------
The Agency’s legal authority and promulgated methodology for estab-
lishing treatment standards, and the petition process necessary for requesting
a variance from the treatment standards are su’nm rized in an EPA document
entitled Methodology for Developing BDAT Treatment Standards .
The following tables list the specific proposed BDPLT treatment
standards for the 1 (027, 1(113—1(116, U221, and U223 treatability group.
1(027 BGD-2 1-6
1128—01 .mlm.6
-------
BDAT Treatment Standard
for K027, K113-K116, U221 and U223
(Nonwastewaters)
EITHER INCINERATION OR FUEL SUBSTITUTION AS A METHOD OF
TREATMENT
BDAT Treatment Standard
for K027, K113—K116, U221 and U223
(Was tewaters*)
CARBON ADSORPTION AS A METHOD OF TREATMENT
*Scrubber water residuals from incineration or fuel substitution
units are not prohibited from land disposal; carbon adsorption treatment is
not required for these scrubber waters.
K027 BGD-2 1-7
1128—01 .mlm.7
-------
Additional BDAT Treatment Standards for K115
(Nonwastewaters)
Maximum for any
Single Grab Sample
Total Composition TCLP
Constituent
(mg/kg) (mg/i)
Nickel
Not Applicable 0.32
Additional
BDAT
Treatment Standards for K115
(Wastewaters)
Maximum for any
Single Grab Sample
Total Composition TCLP
Constituent
(mg/i) (mg/i)
Nickel
O.U7 Not Applicable
K027 BGD-2 1-8
1128-01 .mlm.8
-------
2.0 INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
The purpose of this section is to describe the industry affected by
the land disposal restrictions for K027, Kill, K112, K113, K1lL , K1l5, K116,
U221, and U223 and to present available characterization data for these
wastes.
Wastes identified as K027, Kill, K112, K113, K1114, K1i5, Kl16, U221,
and U223 are specifically generated by the dinitrotoluene (DNT), toluene-
diamine (TDA), and toluene diisocyanate (TDI) manufacturing processes and are
listed in CFR 261.32 and 261.33(f) as follows:
K027: Centrifuge and distillation residues from toluene
diisocyanate production (2nd 3rd).
Kill: Product washwaters from the production of dinitrotoluene
via nitration of toluene.
K112: Reaction by—product water from the drying column in the
production of toluenediamine via hydrogenation of dinitro-
toluene.
1 (113: Condensed liquid light ends from the purification of
toluenediamine in the production of toluenediamine via
hydrogenation of dinitrotoluene.
1(11k: Vicinals from the purification of toluenediamine in the
production of toluenediamine via hydrogenation of dinitro-
toluene.
1 Vicinals are the ortho isomers of TDA. Ortho isomers are removed
before phosgeriation of TDA to TDI to avoid the formation of methylbenzi-
midazolone which reduces the reaction yield.
K027, Klll—K116 BGD 2-1
section.2—O. 1
-------
K115: Heavy ends from the purification of toluenediamine in the
production of toluenedlamine via hydrogenation of dinitro-
toluene.
K116: Organic condensate from the solvent recovery column in the
production of toluene diisocyanate via phosgenation of
toluenediamine.
U221: Toluenediamthe (1st 3rd).
U223: Toluene ditsocyanate (1st 3rd).
2.1 Industry Affected and Process Description
The Agency estimates that there are eight domestic facilities that
produce dinitrotoluene (DNT), toluenediamirie (TDA), and/or toluene diisocya—
nate (TDI). The majority of these facilities are located in the Southern and
Eastern parts of the United States. Table 2-1 lists the number of facilities
for each product, along with potential wastes generated, by state and EPA
region. A simplified flow diagram illustrating the manufacturing processes
generating dinitrotoluene, toluenediamine, and toluene diisocyanate is pre-
sented in Figure 2-1. DNT and TDA are generally produced for use in TDI
production. Additionally, TDA may be produced for use in the manufacture of
dyes or other chemical products. The production level of TDA for these
purposes, however, is believed to be quite low. Almost all TDI is used to
make polyurethanes, including polyurethane foam products, coatings,
elastomers, and adhesives.
K027, K111-K116 BGD 2-2
section.2-O.2
-------
Table 2-1
FACILITIES THAT MAY GENERATE K027, Kill, K112, K113,
KllL , Kl15, AND/OR K116 BY STATE AND EPA REGION
Number of Facilities Wastes Potentially
DNT TDA TDI Generated
3 3 K027, Kill, K112, K113,
K11 1 4, K1l5, K116
0 0 Kill
2 2 2 1 (027, Kill, K112, 1(113
K1lL , 1(115, 1(116
1 1 1 1(027, Kill, K112, 1(115,
Kl 16
Sources:
References 38 and 39.
K027, 1(111—1(116 BGD
section.2-0.3
2-3
State (EPA Region )
Louisiana (VI)
New Jersey (II)
Texas (VI)
West Virginia (III)
-------
Pliosgena
Figure 2—i
Flow Diagram of Processes Generating the
K027. Kill — K116 Waste Codes
Nashwattr
Vent Ca. Kill
8y-froduct timt
End VlcInaJs
Ki 2 KU3 KU4
Dilute
Alkali
Ucke-up
Cotalyit
KUS
a’9b7iC
Liquid
id.nsats)
To’
froduct
Kfl5
l ovy
KOZi
10J
sidua
Solvent
-------
The manufacturing of toluene diisocyanate typically involves three
continuous chemical processes:
1. Nitration of toluene to form dinitrotoluene (DNT);
2. Hydrogenation of DM1 to form toluenediainine (TDA); and
3. Phosgenation of TDA to form toluene diisocyanate (TDI).
As shown in Figure 2-1, toluene is nitrated with nitric acid in the
presence of sulfuric acid, which acts as a solvent and a catalyst. The
two-phase product from the nitration reactor is separated into organic and
acid layers. Spent acid is sent to a recovery unit where the recovered acid
solution is recycled to the reactor. Water, a by-product of the nitration
reaction, is separated in the acid recovery step and used in the DM1 washing
process following acid separation. The organic layer from the acid separation
step, containing the desired product dinitrotoluene (DM1), is purified through
a two— or three-stage washing process. Washwaters from the washing process
form the listed waste Kill.
The DNT product Is dissolved in a solvent (typically methanol) and
is combined with a catalyst (either palladium on carbon or Raney nickel). The
mixture is then sent to a pressurized reactor where hydrogen is introduced.
The product from the hydrogenation reaction is sent to a catalyst recovery
unit where the catalyst is recovered. The crude TDA product is then distilled
through a series of columns. Solvent is removed from the solvent recovery
column and is completely recycled. By—product water resulting from the
hydrogenation of diriitrotoluene is removed in the TDA drying column. The
by-product water forms the listed waste K112. Light ends are removed from the
K027, K111-K116 BGD 2—5
section.2-O.5
-------
light ends separationcolumn and form the listed waste K113. Vicinals (the
ortho isomers of TDA) are removed from the vicinals separation column and form
the listed waste K11ZL In the final distillation step, heavy ends are removed
from the residue separation column and form the listed waste K115.
Following distillation, the purified TDA is dissolved In a solvent,
typically chlorobenzene or o—dichlorobenzene. The resulting mixture is sent
to a series of reactors. Phosgene liquid is fed into the bottom of these
reactors, which are referred to as phosgenators. The crude TDI product from
the phosgenation reaction is then distilled through a series of columns.
Phosgene is recovered in the phosgene recovery column and recycled to the
phosgenators. Solvent is removed from the solvent recovery column and sent to
a separation column where the organic liquid condensate (K116) is separated.
The organic condensate from the solvent recovery step forms the listed waste
K116. Bottoms from the solvent recovery column are sent to the residue
separation column where TDI residue is separated from the overhead TDI
product. The TDI residue forms the listed waste K027.
U221 and U223 are generated from spills, leaks, or discard of
chemicals associated with the production of a commercial chemical product or
manufacturing chemical intermediate having the generic name of TDA or TDI.
For example, a formulator of polyurethanes who disposes of an up—dated stock
of TDI should report this waste as U223.
K027, K111-K116 BGD 2-6
section .2—0.6
-------
While the reaction of amines with phosgene is the most common method
of manufacture for isocyanates, other processes exist that may produce a TDA
or TDI product or manufacturing intermediate. Examples of other isocyanate
processes are the Curtius, Hofmann, and Lossen Rearrangements, Metathesis,
preparation from isocyanate derivatives, and preparation from isocyariic acid.
Regardless of the method of production, U221 and U223 will be generated when
either disposal or release of TDA or TDI commercial chemical products or
off-specification commercial products occur. U221 and tJ223 wastes are then
subject to the proposed regulations discussed in this background document.
2.2 Waste Characterization
Table 2-2 presents a stimm ry of the publicly available character iza-
tion data for K027, Kill, K112, Kl13, Klli , K115, and K116. Characterization
data are not available for U221 or U223. The si’inp ry in Table 2-2 was com-
piled from data in the Listing Background Document for DNT, TDA, and TDI
Production, data based on theoretical calculations, and patent information
supported by unspecified industry data. All available data for each waste
code may be found in the RCRA Confidential Business Information (CBI) Appendix
A. This Appendix can be found in the confidential portion of the docket for
this rulemaking.
As shown in Table 2—2: (1) K027 contains high levels of TDI and TDA
and up to 100% polymers and tar-like materials; (2) Kill and K112 contain
K027, Klll-K116 BGD 2-7
section .2—0.7
-------
Table 2—2
SUMMARY OF PUBLICLY AVAILABLE WASTE CHARACTERIZATION DATA
FOR WASTE CODES K027, Kill, Ki12, K113, K11 1 4, K115, AND K116
Estimated Untreated Waste Concentration (%)++
Major Constituents K027 Kill K112 K113 K114 K115 K116
ORGANIC CONSTITUENTS
BDAT List Constituents
7. Carbon tetra— - —- -— -- 0-75
chloride
114. Chloroform -- 0-7
142. Tetrachioroethene —— —— —— 0—15
143. Toluene -— —— -- -- CBI
56. Aniline CBI 0.01—0.1 0—5 -- ——
Non-BDAT List
Constituents
Toluenediisocyanate 0-50
Isocyanates 3 —- —— -— -- ——
Dinitrotoluenes —— 0—0.3’ —- -- -- --
Mononitrotoluenes -- 0.0045 —— -- -- ——
Dinitrocresols 0.06 —- —— — —
(mostly 2,6—
dinitro p-cresol)
Jitrophenols - 0.0035
t1itroaromatics - 0.0035
(nitrobenzoic acids
and nitrocresols)
2,U—TDA & 2,6—TDA 10-50+ 0.05—0.3 0-37.5 4.5-50 10-50
3,14—TDA & 2,3—TDA —- O-.05-0.3 0-37.5 140—95 0—2.5
o-Toluidine —— 0—0.06 0.6—6 0—3 —-
p-Toluidine 0—0.04 0.4—14 0-2
Polymers & Tar-Like - 90
Materials
Phosgene - -— —— —— -- —— 0-30
Karathane” - 10—50 — -
Methylcyclohexylamine - - -- CBI
Methylcyclohexanone - - -— CBI
TDA Toluenediamine
.2, 1 4—TDA isomer only.
‘Includes nitrophenolics.
**Karat 2fle is the common name of the compound Dinocap
++Most of the data shown for K027 and K111—K116 represent
analysis for organics using capillary GC/MS Method 8270.
One facility reported analysis of K027 using “Total Amine
equivalent ASTM Method D-1638”.
CBI = Confidential Business Information.
—-Data are not available for these constituents.
K027 BGD-2 2-8
-------
Table 2-2 (Continued)
SUMMARY OF PUBLICLY AVAILABLE WASTE CHARACTERIZATION DATA
FOR WASTE CODES K027, Kill, K112, K113, Ki14, K115, AND K1l6
Estimated Untreated Waste Concentration (%)
Major Constituents K027 Kill K1i2 Ki13 K1l K115 K116
INORGANIC CONSTITUENTS
Water CBI CBI CBI CBI -— -- CBI
Ferric chloride - 6
Inorganics 1—4
(H2SOk + HNO 3 ,
Sulfate . Nitrate
Salts)
Spent Catalyst (Ni) -- -— 0-5
OTHER PARAI€TERS
Ash content (%) - 6
Specific gravity -1.22
leating value 6020—9993
(Btu/lb)
TDA Toluenedlamine
+2,ZI TDA isomer only.
* Includes nitrophenolics.
** rathane is the common name of the compound Dinocap
.s.+Most of the data shown for K027 and K1ll-K116 represent
analysis for organics using capillary GC/MS Method 8270.
One facility reported analysis of K027 using “Total Amine
equivalent ASTM Method D—1638”.
CBI Confidential Business Information.
-—Data are not available for these constituents.
K027 BGD-2 2—9
-------
water and 0-1% organic compounds; (3) K113, K114, and K115 are organic waste
streams that contain high levels of TDA; and (14) K116 contains high levels of
chlorinated hydrocarbons including carbon tetrachioride and chloroform.
Additionally, based on manufacturing processes generating K027 and Kl11—K116,
these wastes are expected to contain very low concentrations of metals, if
any, except for K115 which may contain 0—5% spent nickel catalyst. As thdi-
cated in Table 2-2, 1 (027 has a low ash content of 6 percent. Waste codes
1(113-1(116 are also expected to have low ash contents based on the manufactur-
ing processes generating these wastes.
2.3 Determination of Waste Treatability Groups
In cases where EPA believes that constituents present in wastes
represented by different codes can be treated to similar concentrations using
the same technology, the Agency may combine the codes into one treatability
group (53 FR 31145, August 17, 1988).
For waste codes 1(027, K111—K116, U221, and U223, a careful review of
waste generation, waste management practices, and waste characterization data
was conducted to determine whether these waste codes could be combined into
one or more waste treatability groups. Based on this review, two waste
treatability groups have been determined: (1) K027, K113-K116, U221, and U223
and (2) Kill and K112.
1(027, 1(113-1(116, U221, and U223 as generated are usually nonwaste-
waters containing high concentrations of aromatic organonitrogen compounds.
K027 BGD—2 2-10
-------
Specifically, the Agency believes that K027, K113-K116 are expected to contain
high concentrations of TDA and TDI. K116 is also expected to contain high
concentrations of chlorinated hydrocarbons such as carbon tetrachioride and
phosgene. K027, K113, K11 4, and K116 are expected to contain very low concen-
trations of metals, if any. However, available data show that K115 may
contain treatable concentrations of Raney nickel (up to approximately 5%).
The Agency has information showing that facilities generating K027 and
K113 —K116 usually either treat or dispose these wastes in the same or similar
units.
The Agency expects that the major organic constituents that will be
present in these wastes are TDA in U221 and TDI in U223 given that these
wastes contain commercial forms of TDA and TDI and so would be expected to
contain high levels (percent levels) of these constituents. Since TDI and TDA
products are generated from similar manufacturing processes, EPA believes that
any impurities in either commercial products or off—specification products
meeting the listing criteria for U221 and U223 will consist of constituents
similar to those typically shown or expected to be contained in K027 and
K113-K116. As a result, the Agency expects U221 and U223 to show treatment
characteristics similar to these IC wastes. Based on these similarities, the
Agency believes that U221 and U223 are amenable to treatment by the same
treatment technologies that are applicable to 1 (027 and 1(113—1(116. Therefore,
1(027, 1(113-1(116, U221, and U223 are considered to represent a single waste
treatability group.
1(027 BGD—2 2-11
-------
Kill and K112 are generated y similar industries (production of
nitrated aromatic compounds) and similar processes. These two wastes, as
generated, are normally wastewaters containing low concentrations of’ organic
compounds (0-1%). Kill and K1i2 are expected to contain very low concentra-
tions of metals, if any. Kill and Kl12 are often co—disposed or co-treated in
wastewater treatment systems. Therefore, based on waste generation, waste
management practices, and waste characteristics, Kill and K112 comprise a
separate, distinct waste treatability group.
K027 BGD-2 2-12
-------
3.0 APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
In the previous section of this document, the processes generating
K027, K111-K116, U221, and U223 were described and characterization data were
presented for the wastes. In addition, two treatability groups were identi-
fied. This section identifies the treatment technologies that are applicable
for treatment of wastes in these treatability groups and determines which of
the applicable technologies can be considered demonstrated for the purpose of
establishing BDAT.
To be applicable, a technology must theoretically be usable to treat
the waste in question or a similar waste. To be demonstrated, the technology
must be employed in full-scale operation for the treatment of the waste in
question or of a similar waste. Technologies available only or at pilot- and
bench—scale operations are not considered in identifying demonstrated tech-
nologies.
3.1 Applicable Treatment Technologies
The following subsections present applicable treatment technologies
for (1) the nonwastewater and wastewater forms of K027, K113—K116, U221, and
U223 organics, (2) the nonwastewater and wastewater forms of K115 metals, and
(3) the wastewater and nonwastewater forms of Kill and K112 organics. For the
purpose of the land disposal restrictions rule, wastewaters are defined as
wastes containing less than 1% (weight basis) filterable solids and less than
3—1
-------
1% (weight basis) total organic carbon (TOC). Wastes not meeting this defi-
nition are classified as nonwastewaters.
3.1.1 K027, K113—K116, U221, and J223 Treatability Group
Nonwastewaters
As generated, K027, K113-K116, U221, and U223 are generally non—
wastewaters containing high concentrations of aromatic organo-nitrogen com-
pounds. Applicable treatment technologies, therefore, include those that
destroy or reduce the total amount of various organic compounds in the waste.
The Agency has identified the following technologies as potentially applicable
for treatment of 1 (027, 1(113—1(116, U221, and U223 nonwastewaters: incinera—
tion, fuel. substitution, solvent extraction followed by recovery or incinera-
tion of the contaminated solvent, and recycle or reuse.
The Agency believes that incineration of 1(027, 1(113-1(116, U221, and
U223 may generate a nonwastewater residual that may be classified as 1(027,
K113-K116, U221, or U223 such as incinerator ash or filtrate from the
filtration of scrubber water.
3—2
-------
Wastewaters .
Incineration of K027, K113-K1 16, U221, and U223 nonwastewaters may
result in the generation of a scrubber water residual that may be classified
as K027, K113—K116, U221 and U223 wastewaters. These scrubber waters would
contain nondetectable levels of organic constituents since organics are
destroyed during incineration. Therefore, additional treatment of these
residuals for hazardous organic constituents would not be required.
Additionally, the Agency believes that RCRA corrective actions and
CERCLA remedial orders may result in the generation of K027, K113—K116, U221,
and U223-containing wastewaters (as either contaminated ground water, surface
water or leachates). These types of wastewaters are “derived from” K027,
K113—K116, U221, and U223 and are also subject to the land disposal restric-
tions. The Agency has identified the following technologies as potentially
applicable for treatment of hazardous organic constituents in these waste-
waters: biological treatment, solvent extraction, and carbon adsorption.
These applicable technologies destroy or reduce the total amount of hazardous
organic compounds in the waste (biological treatment) or selectively remove
hazardous organic compounds from the waste stream (solvent extraction and
carbon adsorption).
3—3
-------
3.1.2 K115 Metals
Nonwastewaters
K115 as generated is usually a nonwastewater and may contain 0-5%
spent nickel catalyst. Incineration or fuel substitution of 1(115 nonwaste-
waters would be expected to generate small amounts of’ ash that may contain
concentrated levels of nickel (since nickeL is not destroyed in the combustion
process). A nonwastewater residual may also be generated from treatment of
incineration/fuel substitution scrubber waters (e.g., spent filter cart-
ridges). The Agency has identified stabilization as a potentially applicable
technology for treatment of these 1(115 nonwastewater residuals.
Was tewaters
Incineration or fuel substitution of’ 1(115 nonwastewaters may result
in the generation of a scrubber water residual. The residual may contain
concentrated levels of nickel (since nickel is not destroyed in the combustion
process). The Agency has identified the following technology train as poten-
tially applicable for treatment of nickel in this 1(115 wastewater residual:
chemical precipitation followed by sludge dewatering.
3_Li
-------
3.1.3 Kill and K112 Treatability Group
Wastewaters
Kill and K112, as generated, are normally wastewaters containing low
concentrations of organic compounds (less than 1%) and very low concentrations
of metals. The Agency has identified the following technologies as poten-
tially applicable for treatment of the organic constituents in these wastes:
biological treatment, carbon adsorption, and solvent extraction.
Nonwas tewaters
All of the treatment processes presented as potentially applicable
for organic constituents in Kill and K1l2 wastewaters generate nonwastewater
residuals (e.g., spent biomass, spent carbon, and solvent extract). The
Agency has identified fluidized bed, multiple hearth, or rotary kiln incinera-
tion technologies as potentially applicab].e for treatment of these Kill and
Kl 12 nonwastewaters.
3—5
-------
3.2 Demonstrated Treatment Technologies
3.2.1 K027, K113—K116, U221, and U223 Treatability Group
Nonwastewaters
Several of the facilities that generate one or more of the K027,
K113-K116, U221, U223 wastes incinerate or burn them in high temperature
boilers. The Agency is currently aware of three facilities that incinerate
these wastes (two onsite and one offsite) and at least three facilities that
treat these wastes by fuel substitution in high temperature boilers. (Two
facilities that incinerate K027 also treat one or more of K113-K116 by fuel
substitution, and one facility treats K027 by fuel substitution.) Based on
this information, the Agency has determined that fuel substitution and incin-
eration are demonstrated treatment technologies for nonwastewater forms of
K027, K113—K116, U221, and U223.
The Agency has been unable to identify any facilities using solvent
extraction for treatment of’ K027, K113—K116, U221, and L1223 nonwastewaters.
One facility recycles K116 nonwastewaters but also occasionally co—incinerates
this waste with K027.
Wastewaters
The Agency is not aware of any facilities that treat wastewater
forms of the K027, K113-K116, U221, and U223 treatability group. As discussed
3-6
-------
in Section 3.1.1, add .tlonal treatment of hazardous organic constituents in
scrubber waters generated from incineratiol1/fuel substitution is not required.
However, K027, K113-K116, U221, and U223 w stewaters generated from RCRA
corrective actions and CERCLPL remedial ord rs contain hazardous organic
constituents that require treatment. Biological treatment, solvent extrac-
tion, and carbon adsorption are demonstrated on a full-scale level for treat-
ment of wastes that contain organonitrogen compounds (e.g., K103 and K1OL
wastewaters, reference 28, and the Solvents Rule, reference iO). The Agency
therefore believes that since these technologies are demonstrated for treat-
ment of wastes containing similar organic constituents, the technologies are
also demonstrated for treatment of wastewater forms of’ wastes in the K027
treatability.
3.2.2 K115 Metals
Nonwastewaters
The Agency is not aware of any tacilities that treat nickel in K115
nonwastewater residuals using any of the ELpplicable technologies identified in
Section 3.1.2. However, EPA has examined its BDAT treatment performance data
base and determined that stabilization is demonstrated for a similar waste,
F006 nonwastewaters, as described in Secti.on 4.O. Nonwastewater residues from
treatment of’ K115 are expected to include incinerator ash, filtrate from the
filtration of scrubber water, and spent carbon from activated carbon adsorp-
tion of scrubber water. F006 nonwastewaters include wastewater treatment
3-7
-------
sludge from electroplating operations. Both wastes are expected to be com-
prised of solid particles or precipitate mixed with water. Both wastes also
contain high concentrations of nickel. The Agency also believes that none of
the constituents present in K115 nonwastewater residuals are likely to inter-
fere with the treatability of nickel.
Wastewaters
The Agency is not aware of any ficilities that treat nickel in K115
wastewater residuals using any of the applicable technologies identified in
Section 3.1.2. However, EPA has examined its BDAT performance data base and
determined that chemical precipitation followed by sludge dewatering of
wastewaters is demonstrated for the following similar waste, K062 wastewaters,
as described in Section 4.0. Wastewater residues from incineration or fuel
substitution of K115 include scrubber waters that contain high concentrations
of nickel. K062 wastewaters also contain high concentrations of nickel. The
Agency also believes that none of the constituents present in 1 (115 scrubber
waters are likely to interfere in the treatabi].ity of nickel.
3.2.3 Kill and K112 Treatability Group
Wastewaters
The Agency has been unable to identify any facilities that currently
use solvent extraction to treat either Kill or 1(112 wastewaters. However,
3-8
-------
facilities have been identified that treat these wastes by biological treat-
ment or carbon adsorption on a full-scale ]evel. Of the several facilities
that generate Kill and/or Kl12 wastewaters, three facilities currently treat
these wastes in biological treatment units and three facilities use carbon
adsorption either alone or as a polishing 9tep prior to disposal. Therefore,
the Agency has identified biological treatiaent and carbon adsorption as the
demonstrated technologies for wastewater forms of Kill and Kil2.
Nonwastewaters
The Agency has determined that incineration is the demonstrated
treatment technology for rionwastewater for is of Kill and K112. The Agency is
aware of at least one facility that currently treats the nonwastewater
residual derived from the treatment of Kill and K112 by f].uidized bed inciner-
ation on a full-scale level.
3—9
-------
14.0 TREATMENT PERFORMANCE DATA BASE
The Agency does not have any treatment performance data for treat-
ment of K027, K113-K116, 0221, or 0223. For nickel in K115 nonwastewaters and
wastewaters, treatment performance data weie transferred from other previously
tested wastes to develop treatment standards. The basis for this data trans-
fer and the sources of treatment performance data are discussed below. For
organic constituents in 1 (027, 1(113—1(116, 0221, and U223 nonwastewaters and
wastewaters, numerical treatment standards cannot be developed due to the lack
of EPA analytical methods that can satisfactly analyze for the constituents of
concern. To determine whether the demonstrated technologies identified in
section 3.0 provide substantial treatment Cor the constituents of concern, EPA
examined treatment performance data from other similar wastes previously
tested using these technologies. These data are used in this document for
determining which technologies represent proposed BDAT (Section 5.0) and for
developing proposed treatment standards (Section 7.0).
Treatment performance data, to the extent that they are available to
EPA, include the types and concentrations of constituents in the untreated and
treated wastes, values of operating parameters that were monitored at the time
the waste was being treated, values of relevant design parameters for the
treatment system, and data on waste characteristics that affect performance of
the treatment technology. Table Z 1 presents data on waste characteristics
that affect performance of the demonstrated treatment technologies, incin-
eration and fuel substitution, for waste codes 1(027, 1(113—1(116. (As discussed
u-i
-------
in Section 2, characterization data are no: available for U221 and U223;
however, these wastes are expected to contain high concentrations of TDA and
TDI.) Available treatment performance data and data for waste characteristics
that affect performance for incineration for waste codes 1 (015, K086, and F02Z
are presented in Tables k-2 through 14_1 , respectively. These data have not
been corrected for analytical accuracy. Aocuracy—adjustment of data is
discussed in Section 7.0 of this background document. Table 4—5 summarizes
the operating data that correspond to the information presented in Tables Z 1
through L i4• A discussion of the methodology used to identify treated wastes
from which treatment performance data are being transferred is included in
Appendix B of this document. Table U—6 presents available treatment per-
formance data and operating data for carbon adsorption treatment of 1(103 and
K10 1 4 wastewaters. These data have not been corrected for analytical accuracy.
Accuracy—adjustment of data is discussed in Section 7.0 of this background
document.
Sources of treatment performance data for nickel for potential
transfer to K115 include those wastes previously tested by stabilization and
lime and sulfide precipitation followed by vacuum filtration. (These tech-
nologies were identified as applicable and demonstrated for treatment of
nickel in 1(115 nonwastewaters and wastewaters in Section 3.0 of this docu-
ment.)
EPA presented data for stabilization of metals in nonwastewaters in
the California List Notice of Data Availability (52 Federal Register 299g2,
-------
August 12, 1987). EPA screened these data to determine whether any wastes are
generated from similar industries or similar processing steps or have similar
waste characteristics as expected for ash enerated from the incineration of
K115. Stabilization of wastewater treatme’ t sludge from electroplating
operations, F006, is the best source of data for transfer to stabilization of
ash generated from incineration of K115 be ause both wastes contain similar
concentrations of nickel. Treatment performance data for stabilization of
F006 are included in Table L _7. These data have been corrected for analytical
accuracy. Accuracy-adjustment of’ data is iiscussed in Section 7.0 of this
background document.
EPA’s database for chemical precipitation in wastewaters is included
in the California List Notice of’ Data Availability (52 Federal Register 29992,
August 12, 1987). EPA screened these data to determine whether any wastes are
generated from similar industries or similar processing steps or have similar
waste characteristics as expected for scrubber water generated from the
incineration of K115. Lime and sulfide precipitation followed by vacuum
filtration of K062 and other metal—bearing characteristic wastes is the best
source of data for transfer to chemical precipitation followed by sludge
dewatering of scrubber water generated from incineration of K115 because both
wastes are expected to contain similar concentrations of nickel. Treatment
performance data for lime and sulfide precipitation followed by vacuum
filtration of K062 are included in Table 4—8. These data have not been
corrected for analytical accuracy. Accuracy-adjustment of data is discussed
in Section 7.0 of this background document.
L _3
-------
Table Li.. 1
WASTE CHARACTERIZATION DATA FOR K027, K113—K116
Bond
Constituents in
Untreated Wastes
K027
Concentration in
Untreated Waste
(ppm)
Boiling Point
(°C)
Dissociation
Energy
( kcal/mole )
TD I
Polyinerized TDI
2,Lt _TDA
Karathane
Ki 13—Ki 15
2,14— & 2,6—TDA
2,3- & 3,14..TDA
o— p-Toluidine
Aniline*
K1 16
Phosgene
Carbon tetrachioride
Chloroform
Tetrachioroethene
U22 1
TDA
U223
TD I
0-500,000
900,000
100,000—500, 000
100,000—500,000
0-500 ,000
0-950,000
0-100,000
100-50,000
0—300,000
0—750, 000
0-70,000
0—150,000
1314
NA
283-285
138 1 140
283-285
283—285
200—202
1814-186
8.2
76.7—77
6 1—62
121
2,350
NA
1 9140
1491 1
19140**
1914
21480**
11495
335
320
3140
1465
19140
2350
Performance data are not available for treatment of K027.
•‘ Data are from Table 2—2, Section 2.0. Data sources include the Listing
Background Document for DNT, TDA, and TDI Production, data based on
theoretical calculations, and patent information supported by unspecified
industry data.
* Constituent in K113 and K11 1 4 only
** Bond dissociation energy for each isomer
NA Not available.
NA
MA
283—285
283—285
14-14
-------
Table 4—2
TREATMENT PERFORMANCE DATA FOR K015: LIQUID
INJECTION INCINERATION
Bond
Boiling Dissociation
Regulated Concentration ( pb)* Point Energy
Constituent Untreated Scrubber Water ( °C) ( kcal/mole )
Anthracene <5,000 <50-210 2 42 2,900
Benzal Chloride 910,000-1,100,000 EO-96 205 1,600
Benzo(b and/or k) <5,000 <50-96 NA 3,990
fluoranthene
Phenanthrene (5,000 (50-58 3 4O 2,900
Toluene <10 15—59 110.6—111 1,620
NA - Not available.
a The operating ranges for the liquid injection incinerator and scrubbing
system during the performance test are sinnm rized in Table L _5.
Source: Reference 27
L _5
-------
Table Z _3
TREATMENT PERFORMANCE DATA FOR K086: ROTARY
KILN INCINERATION
Bond
Dissociation
Concentration Boiling Energy
Regulated in Waste (ppb)* Point (kcal/rnole)
Constituent Untreated Scrubber Water ( °C ) ____________
Acetone CBI <0.005 56.5 9L 5
Bis(2—ethylhexyl) CBI <0.010 385 6,565
phthalate
n—Butyl alcohol + 117—118 1,635
Cyclohexanone CBI <0.005 155.6 1,665
o-Dichlorobenzene 180.5—181 1,325
Ethyl acetate ** —— 77 1,305
Ethyl benzene CBI <0.005 136.3 1,905
Methanol + -— - 6LL7 1 95
Methylene chloride CBI <0.OC5-
-------
Proposed ____________________
Regulated
Constituent ____________ _________ ________ ________ __________
2-Chloro—1 ,3—
butad iene
3-Chioropropene
1, 1-Dichloroethane
1 ,2—Dichloro—
ethane
1 ,2—Dichloro—
propane
cis—1 ,3—Di—
chioropropene
trans—i ,3—
Dichioropro-
pene
Bis(2—ethylhexyl)
phthalate
Di-n-octyl phthalate
Hexachioroethane
Pentachlorobenzene
Tetrachloro-
dibenzofurans
Pentach loro—
d thenzofurans
Pentachioro—
d ibenzo-p-
dioxins
Hexachioro- <0.0000005-0.051 <0.000037
d ibenzofurans
Hexachioro— <0.0000005—0.01 <0. 000079
dibenzo-p-
dioxins
* The operating ranges for the rotary kiln ir cinerator during the performance test
are surnin rized in Table 14_5 .
ND = Not Detected.
NA = Not Available.
Source: Reference 21
Table 1414
TREATMENT PERFORMANCE DATA FOR F024: ROTARY
KILN INCINERATION
Concentration in Waste (ppm)*
Untreated Scrubber
Waste Ash Water
<0.5—139,721 <0.10 <0.1
0.5_285, 1486 <0.10 <0.1
<0.025-<1O,000 0.005 <0.005
<0.025—11,000 (0.005 <0.005
<0.025-230,000 <0.005 <0.005
<0.025-160,000 <0.005 <0.005
<0.025—290,000 <0.005 (0.005
Boiling
Point
(°C)
59.14
i4 1 4_ 1 45
57-57. 3
83 8LI
96 •14
108
112
Bond Disoc-
iat ion
Energy
( kcal/mole )
955
810
6145
6145
930
790
790
<172—7.63 <0.333—
-------
Table ‘15
SUMMARY OF OPERATING DATA
FOR INCINERATION OF K015, K086, FO2 l, AND K027
Waste Code: K027 K027 K015 K086 F02’I
Liquid Liquid
Injection Fluidized Bed Injection Rotary Kiln Rotary Kiln
Type of Incinerators: ( a) ( b) ( c) ( d) ( e)
OPERATING PARAMETERS
Incineration Chamber
Temperature (°F) 2,OOO—2 3OO 1585. l-1752.8’ 1,780—2,077 1,880—2,053 1,2O1-1,6O
Feed Rate (lb./min.) 83.3’ 18.3—30.0 L1 1 l-6.22 NA, NA
Residence Time (sec.) 1.7 NA NA 0.2 0.1-0.58
Afterburner Chamber
Temperature ( “F) NA NA NA * 2,032-2,056 1,803-2,1’42
Fxn ss oxygen (1) 10—12 7.19—12.2 3.17-5.77 5.0—6.2 5-15
Carbon monoxide (ppm) 75-150 28-255 0_611 1* 3.7-5.0 1-70
Off-Gas Scrubber
Flow rate (gal./min.) NA 11—18 17.1I NA NA
Pressure drop (in. of NA NA 38-’ NA NA
H 2 0)
* The liquid injection incinerator consists of a single chamber. These parameters were measured in that
chamber.
This number represents the rotational speed of the rotary kiln incinerator in rotations per minute, a
surrogate measure of residence time.
+ This number was calculated using a heating value of 10,000 Btu/lb.
++ This number represents the temperature range measured in the free board area of the fluidized bed
Incinerator.
‘‘ Make-up flow rate.
(a) Source: Reference 15.
(b) Source: Reference 16.
(c) Source: Reference 27.
(d) Source: Reference 26.
(e) Source: Reference 21.
1(027 03
-------
Table L_6
TREATMENT PERFORMANCE DP.TA FOR K103 AND 1 (104:
CARBON ADSORPTION
Regulated Constituent
1(103 and 1(1014
Concentration (Dom)
Untreated
Treated
Aniline
Benzene
2, 1 4—Dinitrophenol
Ni trobenzene
Phenol
Cyanides (Total)
<1 .5—<3.O
<0.005-0.008
16—57
(3.0-4.5
(1 .5—<3.O
1.7—4.77
<0.03—0.96
<0. 005 -O . 142
0.23—0.38
<0.03
<0.03—0. 15
0.129—0.597
OPERATING PARAMETERS
Feed Rate to the System (lbs/hr)
Feed pH to the System (standard pH urits)
Feed Temperature to the System (°C)
Total Organic Carbon in Treated Waste (mg/i)
Calculated Residence Time (minutes)
Design
Value
65,300 (max)
7.0 (mm)
40
250 (max)
85 (mm)
Operating
Range
52,200—76,000
3.5-10.6
25—38
7-79.3
73— 107
Source: Reference 28
-------
Table 14..7
TREATMENT FERFORJIANCE DATh FOR NICKEL TRANSFERRED
FROM STABILIZATION OF F006 NONWASTEWATER
Untreated Waste Treated Waste*
Concentration Concentration
Total TCLP TCLP
( mg/kg) (mg/i) ( mg/i )
435 0.71 0.05
989 22.7 0.03
259 1.1 0.27
37 0.52 0.02
701 9.78 O.O 4
19, 4OO 730 <0.06
13,000 152 0.11
23,700 6Z 4 O.O
5,730 16.1 0.02
* These are accuracy corrected values.
Source: Reference 22
i4.1C
-------
Table L ..8
TREATMENT PERFORMANCE DATA F0 NICKEL TRANSFERRED FROM LIME
AND SULFIDE PRECIPITATION FOLLOWED BY VACUUM FILTRATION OF K062 WASTEWATER
Untreated K062 Treated K062
Waste Concentration Wastewater
( ppm) ( ppm )
669 0.36
712 0.33
382 0.39
Source: Reference 23
4—11
-------
5.0 IDENTIFICAT ON OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT)
This section presents the Agency’s rationale for determining best
demonstrated available technology (BDAT) f’or K027, K113, KllZ , K115, K116,
U221, and U223 nonwastewaters and wastewat’?rs. BDAT for Kill and K112 has not
been identified, and this treatability gro’.ip is not discussed in this section.
BDAT must be specified for all streams assDciated with the management of the
listed waste or wastes; this pertains to the original waste as well as any
residual waste streams generated by the treatment process.
The Agency determines BDAT based on a review of the available
treatment performance data. If data are available for only one technology
treating a waste, then that technology is “best”. If data are available for
more than one technology, the data are examined to determine whether one or
more of the technologies performs significantly better than the others. All
treatment performance data used for determination of whether a technology
performs significantly better is first corrected for accuracy, as discussed in
EPA’s publication Methodology for Developing BDAT Treatment Standards and in
Section 7.0.
The technology that performs be ;t on a particular waste or waste
treatability group is then evaluated to d termlne whether it is “available.”
To be available, the technology must (1) be commercially available and (2)
provide “substantial” treatment of the waste, as determined through evaluation
of treatment performance data. In determining whether treatment is
5—1
-------
substantial, EPA considers data on a treatment technology’s performance on a
waste similar to the waste in question provided that the similar waste is at
least as difficult to treat. If it is det ’ rmined that the best technology is
riot available, then the next best technology is evaluated, and so on.
The determination of BDAT for organics in 1(027, 1(113-1(116, U221, and
tJ223 is discussed in Section 5.1 for nonwastewaters and in SectIon 5.2 for
wastewaters. The determination of BDAT fo nickel in nonwastewater and
wastewater forms of 1(115 is presented in Ss!ction 5.3.
5.1 Determination of BDAT for 1(027, K113-K116, 1J221, and U223 Nonwaste—
water Organics
5.1.1 Identification of BDAT
As discussed in Section 3.2, incineration and fuel substitution are
demonstrated technologies for treating organics in nonwastewater forms of
1(027, K113—K116, U221, and U223. The Agenoy has been unable to identify any
other demonstrated technologies for these wastes; therefore, incineration and
fuel substitution are the “best” technologies for treatment of organics in
1(027, K113-K116, U221, and 1.1223 nonwastewabers.
The Agency evaluated these technDlogies to determine whether they
meet the two criteria identified above and therefore can be considered
“available” for these wastes. The first criteria is satisfied since
5-2
-------
incineration and fuel substitution are cornnercially available technologies.
The Agency then evaluated available treatment performance data, to determine
whether incineration and fuel substitution provide-substantial treatment of
the hazardous organic constituents in K027, K113 —K116, tJ221, and U223. As
described below and in Appendix B, incineration and fuel substitution do
provide substantial treatment for these wastes and are therefore available
technologies. The Agency has therefore determined that incineration and fuel
substitution are BDAT for organics in K027, K113—K116, U221, and U223 non-
was tewaters.
5.1.2 Evaluation of Substantial Treat ent by Incineration and Fuel Substi-
tution
The procedure described in this section and in more detail in
Appendix B was used to show that Incineration and fuel substitution provide
substantial treatment for hazardous organic constituents In K027, K113—K116,
13221, and U223. EPA developed the proposed methodology because (1) available
analytical methods may not satisfactorily analyze for the constituents of
concern in these wastes and (2) surrogate parameters or constituent indicators
to measure performance have not been ident;ified for the hazardous constituents
in these wastes.
Figure 5—1 presents a flowchart illustrating the procedure that was
used to show that incineration and fuel substitution provide substantial
treatment for constituents of concern in 1(027, K113-K116, 13221, and 13223
5—3
-------
nonwastewaters. This procedure is consistent with EPA’s methodology for
transfer of treatment data from a tested waste to an untested waste for the
purpose of establishing treatment standards as performance levels. Each step
shown in Figure 5—1 is described in Appendix B. The results of these steps
for 1 (027, 1(113-1(116, U221, arid 1.1223 are discussed briefly below.
Step 1 : Available waste characterization data for K027, K113—K116,
13221, and 13223 were examined to identify “major” constituents of concern.
Major constituents generally consist of toxic constituents found in L 0 CFR
Part 261 Appendix VII identified for the waste as the basis for listing and
other constituents of concern based on high toxicities, concentrations in the
untested waste, and/or the relative diffthulties of incineration (e.g., high
boiling points and high BDE’s (bond disso :iation energies)). The major
constituents of’ concern for 1(027 and K113 -K116 are shown in Table 14 1. Waste
characterization data are not available for 13221 and U223; however, these
wastes are expected to contain constituents similar to or the same as those
listed for 1(027 arid 1(113-1(116.
Step 2 : The BDAT treatment performance database was examined to
identify all waste codes previously tested by incineration or fuel substitu-
tion. This database includes only those tests for which the treatment system
was well-designed and well-operated during the treatment test and for which
substantial treatment of hazardous organic constituents was demonstrated.
5.JJ.
-------
One or more
wcste cods,
identifi*d
No waste codsu
idsntlf lsd
Perform incineration test by
, llung BDAT List ccnitltuents that
are mars difficult to incinetete
t an the constituents of concern
Determine WhSthST Incrn.rctlon
and/or fuel substitution will
provide subitantidi treatirrsflt for
t . tested waste
• Note that reguloted constituents ore, by definition, substantially
treated by the BOAT treatment technology Substantial treatment 1
demonstrated by comparing constituent concentration, In the
untreated woste with corresponding concentration. in the treatment
residuals
F ’ gure 5—1 Flow Chort Iliustroting the
Substantiol Treotmerit by Incineration
Frocedure Used to Show
or Fuel Substitution
Untested waltOs for which incineration and/or fuel subititutian
I is d.monstroted and (1) EPA—Opproved analytical methods are net
available, and (2) surrogate compounds ore not available for
anOiyais
V
Identify major constituents
Examine BOAT performance database to identify waste
codes previously tested by iricinsrotron and/or fuel substitution
V ____
Screen available performance data
(1) Compare industries, process., generating the waste,, and
available waste characteristIcs (2) Evaluate the relat}v.
treatability of the untested casts, by comparing the thermal
coriøuctivltis , of the wastes, the bolflng points, and bond
dissociation energies of constituents in the wastee
Step 1
Step 2
Step 3
Step 4
Step 5
Step 6
______V_____
Identify regulated BOAT List constituents in each waste cod. that
are more difficult to treat than the constituents of concern
in the untested waste, based on boiling points and bond
dis ocjation energies •
V
‘P
—
Determine whether incineration and/or fuel substitution wID
provide substantial treOtment for the untested waste
V
Provide further support by comparing design and operating data
on incinerction arid/or fuel substitution of the untested waste
to tasted wast
5—5
-------
Step 3 : The tested wastes that were identified in Step 2 were
“screened” to identify waste codes that ar? similar to K027, K113-K116, U221,
and U223 and that are more difficult to tr?at than these wastes. Specific-
ally, tested wastes were identified that:
(a) Are generated from similar industries or similar processes
and/or have similar waste criaracteristics as K027, K113—K116,
U221, arid U223;
(b) Have similar or lower thermal conductivities than K027,
K113—K116, U221, and U223; and
(c) Contain regulated BDAT List constituents that are equally or
more difficult to incinerate with respect to bond dissociation
energies arid boiling points than the constituents of concern
K027, K113-K116, tJ221, and U223.
The specific tested wastes that meet these criteria are listed in Table 5—1.
Generally, wastes that are generated from similar industries or
similar processes, and/or that have similar waste characteristics such as
chemical structure and ash content contain both similar waste constituents and
similar waste treatability characteristic . Wastes generated by similar
industries to that of the K027, K113—K116, U221, and U223 treatability group
are K015, 1 (019, K021, K037, 1(087, and FO2 as discussed in Appendix B;
however, none of these wastes are generated from similar processes.
EPA’S BDAT methodology for determining the relative incinerability
of a waste includes a comparison of the thermal conductivity, constituent
boiling points, and constituent bond dissociation energies of the untested
waste with those of other wastes that have been treated by incinerators or
5—6
-------
fuel substitution units and have been treatment tested. Thermal conductivity
Is a measure of heat transfer by conductivity in the waste. The lower the
thermal conductivity, the greater the difficulty to heat the waste to
volatilize the waste constituents. The boiling point of a constituent
represents the degree of difficulty associ.ated with volatilization. The lower
the boiling point, the easier it is to voJ.atilize the constituent in the
incinerator or fuel substitution unit. Once volatilized, a constituent is
destroyed by combustion. EPA believes that the energy required to destroy
constituents can be assessed through a comparison of each constituent’s
activation energy. The Agency uses bond dissociation energies (BDE) as a
surrogate measurement of activation energy because data on activation energy
are rarely available, and the Agency beli ves that constituents with higher
BDE’s are more difficult to destroy than are those with lower BDEs. A
detailed discussion of EPA’s BDAT methodology for determining the relative
incinerability of a waste and specific waste constituents is included in the
Treatment Technology Background Document .
Wastes identified as equally or more difficult to incinerate than
the K027, K113—K116, U221, and tJ223 treatability group are 1 (015, 1(086, and
FO2 4 as discussed in Appendix B.
Step : Specific constituents that were regulated in the wastes
identified in Step 3 that have higher boiling points and bond dissociation
energies (and are therefore more difficult to treat) than the constituents of
concern in 1(027, 1(113-1(116, U221, and U223 were identified for each of the
5—7
-------
constituents of concern. The constituent5 of concern in K027, K113-K116,
U221, and U223 and the corresponding constituents in 1<015, 1<086, and F02 that
are more difficult to treat are listed in Table 5—1. Available treatment
performance data for these wastes are inc]uded in Tables -2 through a-U.
Constituents that have been regulated in K015, K086, and F02 4
(references 27, 26, and 21) are substantially treated by incineration since
substantial treatment was a requirement for determination of incineration as
BDAT for those wastes. Constituents are considered to be substantially
treated if constituent concentrations in the untreated waste are significantly
lower than corresponding concentrations in the treatment residuals. If
incineration or fuel substitution has been shown to provide substantial
treatment in a tested waste for a constituent that is equally or more
difficult to treat than a constituent in an untested waste (with respect to
boiling points and bond dissociation energies, as described above), then these
technologies will also provide substantiaL treatment of the constituent of
concern in the untested waste. EPA also 0elieves that destruction of hazard-
ous organic constituents in a waste is sinilar whether it occurs in an incin-
erator, high temperature boiler, or industrial furnace.
Step 5 : As shown in Table 5-1, EPA has identified several constitu-
ents that were regulated in previously tested waste codes that are more
difficult to treat than the constituents of concern in K027, K113—K116, U221,
or U223. Therefore, based on the above analyses, EPA believes that incin-
eration and fuel substitution provide substantial treatment of major
5—€
-------
Table 5-1
COMPARISON OF CONSTITUENTS IN KOlS, K086, AND F024 THAT ARE MORE DIFFICULT
TO TREAT THAN THE CONSTITUENTS OF CONCERN IN K027, K113-K116, rJ221, AND U223
Constituents of Concern in Constituents in K015, K086, and F02 1 4
K027, K113—K116, U221, and U223 — That are More Difficult to Treat ’
Boiling BDE Boiling BDE
Constituent Point, 0 C Kcal/mole Constituent Point, 0 C kcal/mole
1. TDI 13 2350 Anthracene 2L 2 2900
Phenanthrene 3L O 2900
Benzo(b and/or k) NA Z O3O
fluoran thene
Bis(2—€’thyl hexyl) 385 6U65
phtha late
Di-n—octyl phthalate 385 6565
Pentachlorodibenzo— L OO -50O 2L 9O
p—dioxin
2. TDA 283-285 19L O Phenant.hrene 3140 2900
Benzo(b and/or k) NA 14030
fluoranthene
Bis(2-cthylhexyl) 385 61465
phthalate
Di-n—octyl phthalate 385 6565
Pentachlorodibenzo— 400-500 21490
p—dioxin -
HexachJ.orodibenzo- J400-500 21470
p—dioxin
NA - Not available.
BDE - Bond dissociation energy.
‘The listed constituents are more difficu.Lt to treat because they have higher
boiling points and higher bond dissociatLon energies than the constituents of
concern in K027, K113—K116, U221, and U223. The listed constituents are
substantially treated by incineration and/or fuel substitute. Available
treatment performance data for K015, K086, and F02L are included in Tables
14..2 through 14_14•
5—9
-------
Table 5—1 (Continued)
COMPARISON OF CONSTITUENTS IN K015, K086, AND F024 THAT ARE MORE DIFFICULT
TO TREAT THAN THE CONSTITUENTS OF CONCERN IN K027, K113-K116, 1J221, AND U223
Constituents of Concern in Constituents in KO15, KO86, and F02 1 4
K027, K113—K116, tJ221, and U223 — That are More Difficult to Treat*
Boiling EDE Boiling BDE
Constituent Point, 0 C Kcal/mole Constituent Point, 0 C kcal/mole
3. o- and 200-202 21480 Anthracene 2142 2900
p- Phenant.hrene 3140 2900
Toluidine Benzo(b and/or k) NA 14030
fluoranthene
Bis(2—E’thyl hexyl) 385 61465
phthalate
Di—n—octyl phthalate 385 6565
Pentachlorodibenzo- 400-500 21490
p—dioxin
14. Kora— 138—1140 14911 Bis(2—ethylhexyl) 385 61465
thane phthalate
Di-n—octyl phthalate 385 6565
NA - Not available.
BDE — Bond dissociation energy.
*The listed constituents are more difficu.Lt to treat because they have higher
boiling points and higher bond dissociatLon energies than the constituents of
concern in K027, K113-K116, U221, and U2:3. The listed constituents are
substantially treated by incineration and/or fuel substitute. Available
treatment performance data for K015, K08’5, and F024 are included in Tables
14-2 through 14—14.
5-10
-------
constituents of concern in K027, K113—K116, U221, or U223 since it has been
shown in Step L that these treatment technologies provide substantial treat-
ment for constituents that are more difficult to treat.
Step 6 : In Table k-5 of Section LLO, design and operating data for
incineration and/or fuel substitution systems currently treating K027,
K113—K116, U221, and/or U223 are compared to design and operating data for
treatment systems from the BDPIT performance database for the waste codes
selected in Step 3. As shown in the table, the operating ranges for BDAT
incineration units (liquid injection for K015, rotary kiln for K086 and FO2 4)
on tested waste codes are similar to the operating ranges for the liquid
injection and fluidized bed incineration units treating K027. EPA believes
that the similarity in design and operation of incinerators and fuel sub-
stitution units treating these wastes provides additional support for the
conclusion that incineration and/or fuel substitution provide substantial
treatment for K027, K113—K116, U221, or U 23 and therefore are appropriate as
BDAT for these wastes.
5.2 Determination of BDAT for K027, K113-K116, U221, and U223 Wastewater
Organics
The specific wastewaters of concern for organics treatment are
contaminated surface a d ground waters frcm RCRA corrective actions and CERCLA
remedial actions and leachates from landf .lls containing K027, K113—K116,
U221, or U223 wastes. Scrubber waters from incineration or fuel substitution
5—11
-------
of these wastes are not expected to contain treatable concentrations of
organics, if any, and are not prohibited from land disposal.
As discussed in Section 3.2.1, carbon adsorption, solvent extrac-
tion, and biological treatment have been identified by the Agency as demon-
strated treatment technologies for wastewal:er forms of the 1 (027, 1(113—1(116,
tJ221, and U223 treatability group. The Agi!ncy is not aware of any facilities
that treat K027, 1(113-1(116, U221, or U223 wastewaters and does not have
performance data for treatment of these wastes. However, the Agency does have
data for solvent extraction and activated carbon adsorption treatment of
wastewaters that contain aromatic organonitrogen compounds that are similar to
the constituents of concern in 1(027, 1(113-1(116, 1J221, and U223 (see the BDAT
Background Document for K103/K10 1 4, reference 28). The Agency does not have
data for biological treatment for these constituents. The available data for
carbon adsorption presented in Table 1I 6 show treatment of wastewaters con-
taining aromatic organonitrogen compounds at concentrations similar to those
expected for 1(027, K113—K116, U221, and t1223 wastewaters, while the data for
solvent extraction represent treatment of wastewaters containing high concen-
trations of organonitrogen compounds.
EPA believes that any of the organonitrogen compounds contained in
wastewater forms of the 1(027, 1(113—1(116, t1221, and (1223 treatability group can
easily be adsorbed on carbon. Available characterization data suggest that
the organonitrogen compounds comprising these wastes, as originally generated,
are aromatic in nature and thus, their chemical structures and physical
5—12
-------
properties (e.g., high molecular weight) make them amenable to treatment by
carbon adsorption. Therefore, based on a eview of these data and a
comparison of the expected waste concentrations, EPA has determined that
carbon adsorption is best technology for K’J27, K113-K116, (1221, and (1223
was tewaters.
The Agency then evaluated the available data to determine whether
carbon adsorption can be considered “available” for treatment of K027,
K113—K116, (1221, and (1223 wastewaters, in terms of the commercial availability
and treatment effectiveness of the technology. Carbon adsorption is a com-
mercially available technology that is commonly used for wastewater treatment.
The Agency’s performance data for carbon adsorption treatment of K103 and K1OLs
show that the technology provides substantial treatment for the constituents
present in K103 and K10 1 4 wastes. Hazardous organic constituents that are
expected to be present in K027 4 K113—K116, U221, and U223 wastewaters based on
their demonstrated mobility in water (as discussed in the Listing Background
Documents for these wastes and reference 37) are dinitrotoluenes, toluene-
dlainines, aniline, tetrachloroethene, chloroform, carbon tetrachloride, o- and
p-toluidine and phosgene.
The performance data that are available for K103 and K1O I does not
include treatment for any of these constit.uents with the exception of aniline.
However, the Agency believes that since carbon adsorption provides substantial
treatment for other organonitrogen compounds that are present in K103 and K1O1
such as 2,k-dlnitrophenol and nitrobenzene, the technology will also provide
substantial treatment for the organonitrogeri compounds that are expected to be
present in K027, K113—K116, U221, and (1223 wastewaters. Furthermore, the
5—13
-------
molecular size and structure (complex, branched ring compounds) of the
constituents in K027, K113-K116, U221, and U223 makes them amenable to removal
by adsorption on activated carbon. Therefore, EPA has determined that carbon
adsorption is an available technology for K027, K113—K116, 11221, and 11223
was tewaters.
Based on the above reasoning, the Agency is proposing carbon adsorp-
tiori as BDAT for the wastewater forms of 1(027, K113—K116, 11221, and 11223.
5.3 Determination of BDAT for Nickel in K115
Characterization data for nickel are not available for treatment
residuals generated from incineration or fuel substitution of K115. However,
based on available characterization data for nickel for untreated K115 wastes
and available treatment. performance data for other nickel—bearing wastes
previously tested by incineration, the Agency believes that treatment
residuals generated from the incineration or fuel substitution of K115 contain
treatable concentrations of nickel. Furthermore, transfer of treatment
performance data from previously tested wastes for the purpose of developing
treatment standards for nickel in K115 is technically feasible as discussed in
Section 3.2.2. Treatment performance data for nickel, presented in Tables -7
and I4 8, are transferred from wastes determined by the Agency to be similar to
nonwastewater and wastewater forms of K115 (F006 and 1 (062, respectively) as
discussed in Section LLO. As discussed i i the background documents for F006
and 1(062, references 22 and 23, these treatment perfortnance’data were reviewed
5—14
-------
and were determined to represent operation of well-designed and well-operated
systems, that sufficient quality assurance/quality control measures were
employed to ensure the accuracy of the data, and that the appropriate measures
of performance were used to assess the perf’ormance of the treatment tech-
nologies.
The Agency has determined that stabilization of K115 nonwastewaters
and chemical precipitation followed by sludge dewatering for K115 wastewaters
are the best technologies for these wastes.
The Agency then evaluated the available data to determine whether
these technologies are “available”. Stabilization and chemical precipitation
followed by sludge dewatering, are considered to be commercially available and
provide substantial treatment for nickel. Therefore, stabilization and
chemical precipitation followed by sludge dewatering are “available” for the
purpose of establishing BDAT.
Based on the above discussion, EPA is proposing stabilization as
BDAT for nickel in K115 nonwastewaters and chemical precipitation followed by
sludge dewatering as BDAT for nickel in K115 wastewaters. The Agency is
soliciting characterization data for K115 combustion residues to verify the
assumption that these wastes contain treatable concentrations of nickel.
5—1 £5
-------
5 .L Summary of Proposed BDAT for the K027, K113-K116, U221, and U223
Treatability Group
As discussed in 5.1 above, EPA is proposing incineration and fuel
substitution as BDAT for organics in K027, K113-K116, U221, and U223 nonwaste-
waters. As discussed in Section 5.2 above, EPA is proposing carbon adsorption
as EDAT for the treatment of organic constituents in K027, K113-K116, U221,
and U223 treatability group wastewaters other than scrubber waters. In
addition, as discussed in Section 5.3 aboire, EPA is proposing stabilization as
BDAT for nickel in 1 (115 nonwastewaters and chemical precipitation followed by
sludge dewateririg as BDAT for nickel in 1(115 wastewaters. The proposed BDAT
regulations do not preclude a facility from recycling operations provided that
the terms of exclusion or exemption speciried in L$O CFR Part 261.2 are met.
5-16
-------
6.0 SELECTION OF REGULATED CONSTITUENTS
This section presents the rationale for the selection of constitu-
ents being proposed for regulation in the K027, K113-K116, U221, and U223
treatability group. Since treatment standards for the Kill and K112 treat—
ability group are not addressed in this proposed rule, this treatability group
is not discussed in this section. Generaily, constituents selected must
satisfy the following criteria:
1. They must be on the BDPIT List of regulated constituents.
(Presence on the BDAT List implies the existence of approved
methods for analyzing the constituent in treated waste matri-
ces.)
2. They must be present in, or be suspected of being present in,
the untreated waste. For (!xample, in some cases, analytical
difficulties (such as mask.Lng) may prevent a constituent from
being identified in the untreated waste, but its identification
in a treatment residual may lead the Agency to conclude that it
is present in the untreated wasta.
3. Where treatment perf’ormanc’! data from another constituent are
being transferred, the selected constituent(s) being proposed
for regulation must be easier to treat than the constituent(s)
from which performance data are transferred. Factors to assess
K027 BGD-l 6—i
-------
the ease of treatment vary according to the technology of’
concern. For Lnstance, for incineration, factors include bond
dissociation energies, thermal conductivities, and boiling
points.
Section 2.0 presented waste characterization data for the K027 and
1 (113—1 (116 waste codes. Major organic constituents of concern in these wastes
such as karathane, TDI, TDPL, and o- and p- toluidine would be considered for
proposed regulation; however, as was discussed in Section 1.0, these constitu-
ents cannot be analyzed due to a lack of satisfactory analytical methods.
Furthermore, as discussed in Section LLO, no treatment performance data are
available for these constituents. Therefore, EPA is proposing to set a
treatment technology as BDAT for organics in the K027, K113—K116, U221, and
U223 treatability group, rather than propose development of treatment per-
formance levels for individual constituent;s.
A review of the inorganic waste characterization data identified
spent nickel catalyst in untreated 1(115. Since metals are not treated in
either incineration or fuel substitution processes, which are the proposed
BDAT for organics in K115, the Agency is proposing to regulate nickel in
nonwastewater and wastewater residuals of’ K115 based on treatment performance
data from other waste codes as was discus:3ed in Section 4.0.
K027 BGD—1 6—2
-------
7.0 DEVELOPMENT OF BDAT TREATMENT ST NDP RDS
The Agency bases treatment standards for constituents on the per-
formance of well—designed and well—operated BDP 1 T treatment systems. These
standards must account for analytical limitations in available treatment
performance data and the data must be adjusted for variabilities related to
treatment, sampling, and analytical techniques and procedures.
BDAT treatment standards are determined for each constituent by
multiplying the arithmetic mean of accuracy-adjusted constituent concentra-
tions detected in treated waste by a “variability factor” specific to each
constituent.
Constituent concentrations are adjusted to take into account
analytical interferences associated with the chemical make-up of the sample.
Generally, treatment performance data are corrected for accuracy as follows:
(1) a matrix spike recovery is determined for each BDAT list constituent
detected in the untreated or treated wast!s; (2) an accuracy correction factor
is determined for each constituent by divLding 100 by the matrix spike
recovery (in percent) for that constitueri;; and (3) treatment performance data
for each constituent are corrected by multiplying the reported concentration
of the constituent by the corresponding accuracy correction factor.
Variability factors correct for normal variations in the performance
of a particular technology over time and are designed to reflect the 99th
7-1
-------
percentile level of performance that the technology achieves in commercial
operation. (For more information on the principles of calculating variability
factors, see EPA’s publication, Methodology for Developing BDP T Treatment
Standards. ) For details on accuracy adjustment of treatment performance data
and the calculation of variability factors for nickel in K115, see the F006
and K062 background documents, references 22 and 23, from which treatment
performance data and standards were transferred.
Where EPA has identified BDAT for a particular waste or waste
treatability group, but because of analytical limitations cannot develop
specific concentration-based treatment standards for that waste, the Agency
can require the use of that treatment technology as the BDAT treatment
standard. The Agency is proposing incineration or fuel substitution as the
BDAT treatment technology standard for K027, 1C113-K116, U221, and U223 non-
wastewaters, and carbon adsorption as the BDAT treatment technology standard
for K027, K113—K116, U22l, and U223 wasteuaters other than scrubber waters.
For K115 nonwastewater and wastewater residuals, the Agency is
proposing concentration-based treatment standards for nickel. These proposed
standards are shown below.
Treatment standards for the Kill and K112 treatability group are
being deferred as discussed in Section 8.).
7—2
-------
K115 Nonwastewater Residual
BDAT: Stabilization
Constituent
NIckel
Maximum for any Single Grab Sample
Tot. l Composition TCLP
j g/kg) (mg/i)
Not Applicable
0.32
K115 Wastewater Residual
BDAT: Chemical Precipitation followed by Sludge Dewatering
Constituent
Nickel
Maximum for any Single Grab Sample
Total Composition TCL.P
gIkg) (mg/i)
0.147
Not
Applicable
7—3
-------
8.0 DETERNINATION OF THE REGULATORY APPROACH FOR THE Kill AND K112
TREATABILITY GROUP
As described in Section 3.1.2, KIll and 1(112, as generated, are
wastewaters and generally contain 0—1% organic compounds. Applicable
technologies for treatment of Kill and K112 wastewaters include those that
destroy or reduce the total amount of various organic compounds in the wastes.
The following technologies were identified as potentially applicable for
treatment of Kill and K112 wastewaters: (1) biological treatment, (2) carbon
adsorption, and (3) solvent extraction. The technology identified as
potentially applicable for treatment of Kill and Kl12 nonwastewaters was
incineration.
Based on telephone contacts with the eight facilities producing DNT,
TDA, and/or TDI, the Agency identified two demonstrated treatment technologies
for Kill and 1(112 wastewaters: biological treatment and carbon adsorption.
The Agency also identified fluidized bed incineration as a demonstrated
technology for treatment of sludge, a noni astewater form of Kill and 1(112,
derived from wastewater treatment of Kill and Kl12.
To be considered an available technology for treatment of Kill and
1(112, the demonstrated technology must provide “substantial treatment” for
constituents of concern in the wastes or ;imilar wastes. As discussed
previously, treatment performance data are not available for biological
8—1
-------
treatment or carbon adsorption followed by incineration of the spent carbon
Kill and K112. The Agency has not determined whether these technologies
provide substantial treatment for Klli and K112. This is because the Agency
feels that further study should be made of all available treatment options and
treatment performance data before proposing either a gross parameter indicator
of performance, or BDAT as a method of treatment. These studies would
compromise valuable resources and time the Agency is currently allocating to
address other wastes that may be otherwise restricted from land disposal if
EPA fails to develop standards by 1990. Finally, since these wastes were
listed after the effective dates of the 1S8L RCRA amendments and land disposal
of these wastes is not subject to either ‘soft hammer” or “hard hammer”
provisions. Therefore, the Agency has decided to address these waste codes at
a later date.
8—2
-------
9.0 REFERENCES
1. U.S. EPA, Test Methods for Evaluating Solid Waste, SW _ 8146 Third Edition ,
Office of Solid Waste and Emergency Response, Washington, D.C., November
1986.
2. U.S. EPA, Test Methods for Evaluating Solid Waste, SW-846 Second Edition ,
Office of Solid Waste and Emergency Response, Washington, D.C., July 1982.
3. AppendIx I. Federal Register , Volume 51, Number 216, November 7, 1986,
page 406147.
4. American Water Works Association, and Water Pollution Control Federation,
Standard Methods for the Examination of Water and Wastewater, Sixteenth
Edition , Washington, D. C., American Public Health Association, 1985.
5. American Society for Testing and Materials, 1986 Annual Book of ASTM
Standards Petroleum Products, Lubricants, and Fossil Fuels , Philadelphia,
Pennsylvania, 1986.
6. U.S. EPA, Methods for Chemical Analysis of Water and Wastes , Environmental
Monitoring and Support Laboratory, Cincinnati, Ohio, EPA-600/ 1 4—79-020,
March 1979, revised 1983.
7. U.S. EPA, Generic Quality Assurance Project Plan for Land Disposal Re-
strictions Program (BDAT) . EPA/530—SW-87-O11. Office of Solid Waste,
Washington, D.C. March 12, 1987.
8. S-Cubed. 19814. Analytical Results for the TDI and MDI Manufacturing
Facilities of the BASF Wyandolte Corporation, Geismar, LA. May 19814.
(CONFIDENTIAL BUSINESS INFORMATION)
9. S-Cubed. 1983. Analytical Results for the TDI and MDI Manufacturing
Facilities of Rubicon Chemicals, Inc. , Geismar, LA. December 1983.
(CONFIDENTIAL BUSINESS INFORMATION)
10. Mobay Chemical Corporation. 1981. Response to U.S. EPA 3007 Question-
naire for Baytown, TX and New Martinsville, WV plants. April 24, 1981.
(CONFIDENTIAL BUSINESS INFORMATION)
11. Dow Chemical. 1981. Response to U.S. EPA 3007 Questionnaire for
Freeport, TX plant. April 3, 1981. CONFIDENTIAL BUSINESS INFORMATION)
12. Olin Chemicals (formerly Allied Chemi als). 1981. Response to U.S. EPA
3007 Questionnaire for Moundsville, WJ plant. March 6, 1981. (CONFIDEN—
TIAL BUSINESS INFORMATION)
13. Olin Chemicals. 1981. Response to U.S. EPA 3007 Questionnaire for Lake
Charles, LA plant. April 20, 1981. (CONFIDENTIAL BUSINESS INFORMATION)
9—1
-------
114. USEPA. U.S. Environmental Protection Agency, Waste Identification Branch.
Characterization of Waste Streams Listed in 40 CFR Section 261 .
15. Olin Corporation. September 1988. Response to 3007 letter from R.
Campbell, Olin Corporation to J. Carra, EPA/OSW.
16. Mobay CorporatIon. July 1988. Report of RCRA Trial Burn Results for a
Fluldized Bed Incinerator . Volume I.
17. Mobay Chemical Corporation. 1981. Response to U.S. EPA 3007 Question-
naire for Baytowri, TX and New Martlnsville, WV plants. April 24, 1981.
(CONFIDENTIAl.. BUSINESS INFORMATION)
18. Olin Chemicals (formerly Allied Chemicals). 1981. Response to U.S. EPA
3007 Questionnaire for Moundsville, WV plant. March 6, 1981. (CONFIDEN-
TIAL BUSINESS INFORMATION)
19. U.S. EPA Listing Background Document Por Dinitrotoluene, Toluene diamine,
and toluene Diisocyanate Production.
20. S—Cubed. 19814. Industry Waste Profile for RCRA Solid Waste from Indus-
trial Organic Chemicals Industry. Toluene Diisocyanate (TDI) from
Toluene. May 19814. (CONFIDENTIAL BU SINESS INFORMATION)
21. USEPA 1988. U.S. Environmental Proteotion Agency. Office of Solid Waste.
Best Demonstrated Available Technology (BDAT) Background Document for
F024) . December 1988.
22. USEPA. 1988. U.S. Environmental Protection Agency. Office of Solid
Waste. Final Best Demonstrated Available Technology (BDAT) Background
Document for F006 . August, 1988. pp. 5—5, 5—6, and 7-3.
23. USEPA. 1988. U.S. Environmental Protection Agency. Office of Solid
Waste. Proposed Best Demonstrated Available Technology (BDAT) Background
Document for K062 . AprIl, 1988.
24. U.S. EPA. 1988. U.S. Environmental Protection Agency. Office of’ Solid
Waste. Final Draft Proposed Guidance Manual (BDT) Interim Guidance for
the Treatment of Contaminated Soil at CERCLA and RCRA Corrective Action
Sites . July 28, 1988.
25. U.S. EPA. 1987. U.S. EPA, OSW. Land Disposal Restrictions Summary, Vol.
2, California List Waste. October 1987.
26. U.S. EPA. 1988. U.S. Environmental Protection Agency. Off Ice of Solid
Waste. Best Demonstrated Available Technology (BDAT) Background Document
for K086 Solvent Wash . August, 1988. Volume 15 (Non CBI version).
9—2
-------
27. U.S. EPA. 1988. U.S. Environmental Protection Agency. Office of Solid
Waste. Proposed Best Demonstrated Available Technology (BDAT) Background
Document for K015 . April, 1988. Volume I.
28. U.S. EPA. 1988. U.S. Environmental Protection Agency. Office of Solid
Waste. Final Best Demonstrated AvailaDle Technology (BDAT) Background
Document for K103 and K1OLL . August, 1 88. pp. 4—5 thru i4—21, Section
5.0, 7-7 and 7—8. Volume 7.
29. Radian Corp. 1986. U.S. Environmental Protection Agency. Submitted to
Texas Water Commission. Trial Burn Plan for Mobay Chemical Corp. Liquid
Waste Incinerator . May 1 4, 1986.
30. Oppelt, Timothy E. 1987. Incineration of Hazardous Waste: A Critical
Review. pp. 558-586, Vol., 37, No. 5. May 1987.
31. Federal Register , Vol. 52, August 12, 1987, pp. 29992_3OOL O.
32. Dean, J.A. (ed), Lange’s Handbook of Chemistry 12th ed. , McGraw—Hill,
1979, pp. 8 — 11 .
33. Sanderson, R.T., Chemical Bonds and Bond Energy , Arizona State University,
Academic Press, New York and London, 1971.
31 . Windholz, Martha, editor. The Merck Index , 10th edition. Rathway, NJ:
Merck & Company.
35. Verchueren, Karel. 1983. Handbook of Environmental Data on Organic
Chemicals . 2nd Edition. pp. 575-576. NY: Van Nostrand Reinhold
Company, Inc.
36. Weast, R.C., editor. 1980. CRC Handbook of Chemistry and Physics , 61st
edition. p. C—13ZL Boca Raton, FL: CRC Press, Inc.
37. D.S. Gilbert. Fate of TDI and MDT in Air, Soil, and Water , International
Isocyanate Institute, Inc. Journal of Cellular Plastics. Volume 2 1 -March
1988.
38. Radian Corporation. August 1988. Contact Memoranda, ID of Genera-
tors/Treaters of K027 Waste Group frori H. Weiner/C. Hong, Radian Corp. to
J. Labiosa, EPA/OSW.
39. SRI International. 1985 Directory of Chemical Producers. United States
of America .
40. U.S. EPA. 1986. U.S. Environmental Protection Agency. Office of Solid
Waste. Best Demonstrated Available Technology (BDAT) Background Document
ofr FOO1-F005 Spent Solvents . November 7, 1986. Volume 2. p. 5-79.
9—3
-------
Appendix A
C8I WASTE CHARACTEL IZATION DATA
-------
Appendix B
APPLICATION OF THE SECTION 5.1.2 METHODOLOGY
ON THE K027, K113-K116, U221, &ND U223 TREATABILITY GROUP
K027, K11i—K116 BD—3 B—i
1207—01 .nrj. 1
-------
The methodo .ogy outlined in Section 5.1 was applied to the K027
treatability group to show that incineration and/or fuel substitution will
provide substantial treatment of the hazardous constituents in nonwastewater
forms of K027, K113-K116, U221, and U223. Each step, shown in the flowchart
of Figure 5—1 and described in Section 5.1, is repeated below along with
results of its application to the K027 treatability group.
Step 1 : Examine available waste characterization data for K027 and
K113-K116 and identify major corstituents of concern.
Characterization data for K027 and K111-K116 are presented in Table
2-2 of Section 2.0. Many of the constituents that characterize these waste
codes are not on the BDAT List of hazardous constituents because of the
difficulties associated with analyzing for the constituents in complex waste
matrices (as discussed in Section 1.0). However, these constituents are major
constituents of concern for the K027 waste treatability group as discussed
below.
Major constituents of concern are those which demonstrate high
toxicity, high concentrations in the untreated wastes, and/or a high degree of
difficulty for treatment. EPA’s BDAT methodology for determining the relative
difficulty in incineration of different hazardous constituents includes a
comparison of the boiling points and bond dissociation energies of the con-
stituents. As shown in Table 2-2, karathane, TDI, TDA, and carbon
tetrachioride are expected to be present in the untreated wastes at highest
concentration.
K027, K111—K116 BD—3 B—2
1207-01 .nrj.2
-------
In addition, karathane, TDI, and o- and p-toluidine have the highest bond
dissociation energies of the constituents present in the untreated wastes
(U,911 keal/mole, 2,350 kcal/mole, and 2, 480 kcal/mole, respectively).
2,U—TDA and 2,6-TDA also have the highest boiling points of 283—285°C.
Therefore, based on the high toxicity, high concentrations in the untreated
wastes, and high degree of difficulty to incinerate, the following
constituents have been identified as the major constituents of concern for the
K027 waste treatability group: karathane, TDI, 2, 4— and 2,6—TDA, and o- and
p-toluidine.
Step 2 : Examine the BDAT performance database to identify all waste
codes previously tested by incineration processes (i.e.,
incineration and/or fuel substitution).
As discussed in Section 5.0 (Step 2), the BDAT incineration database
was chosen for examination in this methodclogy since it is best suited to the
land disposal restriction regulations. Pi rformance data obtained from 12
incineration treatment tests performed by the BDAT program presently consti-
tute EPA’s BDAT incineration performance database. The incineration database
includes both treatment performance data (concentrations of hazardous constit-
uents detected in the untreated and treated wastes) and corresponding design
and operating data for the Incineration s stems.
For the BDAT program, incineration tests were performed only on
incinerators operating under 40 CFR Part 2614 Subpart 0 or Part 265 Subpart 0,
K027, K111—K116 BD—3 B—3
1207-01 .nrj.3
-------
or on fuel substitution units operating under O CFR Part 266. Subsequent to
each treatment test, EPA performed an engineering analysis of’ the treatment
system’s operation during the treatment test to determine whether the treat-
ment system was well-designed and well—operated. The determination of whether
a treatment system is well-designed and well—operated is based upon whether
the treatment system was operating within design operating parameters during
the treatment test. Additionally, PA reviewed the performance data to
determine whether the treatment system provided substantial treatment for the
constituents of concern (i.e., regulated constituents) in the tested waste.
If the treatment was determined to be well-designed and well-operated and
substantial treatment was shown, the Agency included the data in the develop-
ment of treatment standards for the tested waste. Where the treatment system
was determined to be poorly-designed or operated, the Agency excluded that
performance data from the incineration dat.abase precluding the use of that
data in the development of treatment standards.
Based on a review of the existing BDPIT performance database, the
following waste codes previously tested by incineration, were identified:
K027, K111-K116 BD—3 B—Lt
1207-01 .nrj . 4
-------
Type of’
Waste Codes Definition in LW CFR Part 261 Incineration Test
KOOl Bottom sediment sludge from the treatment Rotary kiln
of wastewaters from wood preserving
processes that use creosote and/or
pen tachiorophenol.
K015 Still bottoms from the distillation of Liquid injection
benzyl chloride.
K019 Heavy ends from the distillation of Rotary kiln
ethylene dichloride in ethylene dichioride
production.
KO2U Distillation bottoms from the production Rotary kiln
of phthalic anhydride from naphthalene.
K037 Wastewater treatment sludge from the Rotary kiln
production of disulfoton.
KO’48 Dissolved air flotation (DPF) float from Fluidized bed
the petroleum refining industry.
K051 API separator sludge from the petroleum Fluidized bed
refining industry.
K086 Solvent washes and sludges, caustic washes Rotary kiln
and sludges, or water washEs and sludges
from cleaning tubs and equipment used in
the formulation of ink from pigments,
driers, soaps, and stabilizers containing
chromium and lead.
K087 Decanter tank tar sludge from coking Rotary kiln
operations.
Distillation tar residues from the distil—
KiOl lation of aniline—based compounds in the Rotary kiln
production of veterinary pharmaceuticals
from arsenic or organo-arsenic compounds.
K102 Residue from the use of activated carbon Rotary kiln
for decolorization in the production of
veterinary pharmaceuticals from arsenic or
organo-arsenic compounds.
K027, K111—K116 BD—3 B—5
1207—01 .nrj.5
-------
Type of
Waste Codes Definition in UO CFR Part 261 Incineration Test
FO2U Wastes, including but not limited, distil- Rotary kiln
lation residues, heavy ends, tars, and
reactor clean—out wastes, having carbon
content from one to five, utilizing free
radical catalyzed processes (this listing
does not include light ends, spent
filters, and filter aids, spent dessicant,
wastewater, wastewater treatment sludges,
spent catalysts, and wastes listed in
Section 261.32).
Step 3 : Screen the BDPIT incineration database and identify waste
codes that meet the criteria described below.
(a) Identify wastes that are gE nerated from similar industries or
similar processes, and/or have similar waste characteristics as
K027, K113-K116, U221, and U223.
K027, K113-K116, U221, and U223 are generated from the production of
organic chemicals; specifically, from the production of toluene diisocyanate
and/or toluenediamine. Of the wastes previously tested by incineration, 1 (015,
1(019, KO2Z , K037, 1(086, and FO2Z were identified as waste codes that are
generated from similar industries (production of organic chemicals) as 1(027,
K113—K116, U221, and U223. However, none of these wastes are generated from
similar processes as 1(027, 1(113—1(116, 13221, and U223.
1(027, 1(111-1(116 BD-3 B-6
1207—01 .nrj.6
-------
(b) Identify wastes that have :imilar or lower thermal conductivi-
ties than the untested wastes of concern.
Analytical determinations of the thermal conductivities for these
wastes are not currently available; however, the relative thermal conductivi-
ties of the wastes can be compared based on the chemical characteristics of
these wastes. In general, organic constituents have similar thermal
conductivities. Solids will tend to have higher thermal conductiv’ities than
liquids. Metals have a high thermal conductivity, whereas inorganics which
are non—metallic are generally considered to act as insulators and have low
thermal conductivities.
The wastes K015, K019, K02 1 4, K027, K037, K086, K113—K116, and F02Z4,
are generated from the production of orgaiic chemicals; therefore, these
- wastes are expected to have high concentrations of organic constituents and
very low concentrations, if any, of metals. The K086 wastes treated in EPA’s
incineration test are a mixture of solid and liquid wastes. All other waste
streams are expected to be solid or semi—solid waste mixtures. Based on the
discussion above, K086 as a solid and liquid mixture is therefore expected to
have a lower thermal conductivity (I.e., is more difficult to incinerate) than
K027, K113—K116, U221, and U223. The other waste streams, K015, K019, K02L ,
1 (037, and FO2ZI, are expected to have similar thermal conductivities (i.e.,
similar thcinerability) as 1(027, 1(113—1(116, U221, and U223.
1(027, K111-K116 BD—3 B— ?
1207—01 .nrj .7
-------
(c) Identify wastes that contain regulated BDAT List constituents
that are equally or more dii’ficult to incinerate than the
constituents of concern.
The boiling points and bond dissociation energy (BDE) of the pro-
posed regulated BDAT List constituents in 1(015, K019, K02 4, K037, K086, and
F02 were examined. Of these wastes, K015, K086, and F02 1 were identified as
the waste codes that contain proposed reguLated BDAT List constituents that
are more difficult to incinerate, i.e., ha’e higher BDE’s and boiling points,
than K027, K113—K116, U221, and U223 constituents of concern. Characteristics
of the proposed regulated constituents in 1(015, K086, and F02 4 along with the
performance data, if available, are stirm rized in Tables 4-2 through 1 —5 of
Section p.0.
Step 4 : Select constituents from waste codes identified in Step 3
that meet the criteria delineated below.
The waste codes identified in Step 3 are K015, K086, and F02 .
Characteristics of the constituents of concern in the K027, 1(113—1(116, U221,
arid U223 treatability group are summarized in Table 4—1 of Section ILO.
Characteristics of the regulated BDAT List constituents and performance data
were examined to identify constituents that:
(a) Have higher boiling points and bond dissociation energies than
the constituents of concerr in 1(027 and 1(113—1(116.
K027, 1(111-1(116 BD—3 B—8
1207-01 .nrj .8
-------
As mentioned in Step 1, the conscituents of’ concern in 1 (027 and
1(113—1(116 are TDI, TDA, o- and p—toluidine, and karathane.
Based on the waste characterization and performance data presented
in Tables 4—2 and 4-5 of Section 4.0, anthracene, phenanthrene, and benzo(b
and/or k)uluoranthene in 1(015 were identified as constituents that have higher
bond dissociation energies than TDI, TDA, and o— and p-toluidine. In addi-
tion, phenanthrene has a higher boiling point than TDI, IDA, and o— and
p-toluidine. Anthracene has a higher boiling point than karathane, TDI, and
o- and p-toluidine but a lower boiling point (bp 242°C) than TDA (bp
283-285°C). A boiling point is not available for benzo(b and/or k)fluoran-
thene. However, based on its structure, tenzo(b and/or k)fluoranthene is
expected to have a higher boiling point than phenanthrene. Therefore, benzo(b
and/or k)fluoranthene is expected to have a higher boiling point than TDI,
TDA, and o- and p-toluidine.
Based on waste characterization and performance data presented in
Tables )4_3 and 4-5 of Section 4.0, bis(2-ethylhexyl)phthalate was identified
as the only proposed regulated constituent in 1(086 that has a higher bond
dissociation energy than either karathane, TDI, TDPI, or o- and p—toluidine.
In addition, the boiling point for bis(2—ethylhexyl)phthalate is also higher
than the boiling points for the K027 trea ability group constituents of
concern.
1(027, 1(111-1(116 BD—3 B—9
1207—01 .nrj.9
-------
Based on waste characterization and performance data presented in
Tables L _L and 14_5 of Section LO, bis(2—ethylhexyl)phthalate, di—n-octyl
phthalate, pentachloro-dibenzo—p—dioxin, and hexachloro-dibenzo—p—dioxin in
F02 1 1 were identified as constituents that have higher bond dissociation
energies (BDEs) than either TDI, TDA, o— and p—toluidine or karathane.
(Bis(2.-ethylhexyl)phthalate and di-n—octyl phthalate have higher BDEs than all
four constituents of concern in the K027 treatability group;
pentachloro-dibenzo—p-dioxin has a BDE higher than TDI, TDA, and o— and
p-toluidine; and hexachloro—dibenzo-p—dioxin has a higher BDE than TDA.) In
addition, the four constituents identified in FO2 4 all have higher boiling
points than karathane, TDI, TDA, and o- and p—toluidine in the K027
treatability group.
(b) The selected constituents are present in the untreated wastes
at concentrations high enough to allow a determination that
substantial treatment was achieved in the tested waste.
As shown in Tables 1 _2 through the selected constituents
anthracene, phenanthrene, benzo(b and/or :)fluoranthene, bis(2-ethylhexyl)-
phthalate, di-n—octyl phthalate, pentachloro—dibenzo—p—diozin, and hexachioro-
dibenzo-p—dioxin were all present In the untreated wastes at high enough
concentrations to allow determination that substantial treatment was achieved
in the tested waste.
K027, K111—K116 BD—3 B—1O
1207—01 .nrj. 10
-------
Step 5 : Summarize demonstration of substantial treatment.
Summarized below are the constituents identified in Step L along
with their characteristics and the corresponding constituents of concern in
the K027, K113-K116, U221, and U223 treatability group:
As discussed earlier, EPA’S BDAT methodology for determining the
relative difficulty of incineration of difrerent hazardous constituents
involves the comparison of boiling points and bond dissociation energies of
the hazardous constituents. EPA’s approac is based on the belief that the
higher the boiling point, the harder it is to volatilize the constituent and
the higher the bond dissociation energy, the harder it is to destabilize the
constituent. Therefore, based on the above information, anthracene, phenan-
threne, benzo(b and/or k)fluoranthene, bis(2-ethylhexyl)phthalate, di-n—octyl
phthalate, and pentachlorodibenzo-p—dioxin are shown to be more difficult to
combust than TDI and o- and p-toluidine. Phenanthrene, benzo(b and/or k)-
fluoranthene, bis( 2-ethylhexyl )phthalate, di-n—octyl phthalate, pentachlo—
rodibenzo-p—dioxin, and hexachlorodibenzo-p-dioxin are shown to be more
difficult to combust than TDA and bis(2-ethylhexyl)phthalate and di-n-octyl
phthalate are shown to be more difficult to combust than karathane.
Furthermore, performance data from incineration of these constitu-
ents show that they are substantially tre2Lted by incineration. Therefore,
since substantial treatment is demonstrated by incineration for constituents
that are more difficult to incinerate than TM, TDA, karathane, and o- and
p-toluidine, combustion (as incineration and/or fuel substitution) is expected
K027, Klll-K116 BD—3 B-li
1207—01 .nrj .11
-------
to provide substantial treatment for these major constituents of concern in
the 1(027 treatability group.
In su nary, the above analyses demonstrate that incineration
provides substantial treatment for 1(027, K113-K116, U221, and U223 and,
therefore, support the determination to identify incineration and fuel
substitution as the BDAT method of treatment for 1(027, 1(113—1(116, U221, and
U223.
Step 6 : Compare design and operating data for incineration systems
treating 1(015, 1(086, 1(027, 1(113—1(116, and ‘02 4.
To further support the determination of incineration as the BDAT
method of treatment for 1(027, 1(113—1(116, U221, and U223, EPA compared design
and operating data for incineration systems treating 1(015, 1(086, F0214, 1(027,
and 1(113-1(116. Table 14_5 in Section 14•Ø stimm rizes available operating ranges
for incineration systems treating 1(027, 1(015, 1(086, and F02 1 4. Although
operating conditions vary from facility tc facility and are waste—specific,
the operating ranges for the incinerator treating 1(027 are very similar to the
operating ranges for incinerators treating 1(015, 1(086, and FO2U as indicated
in Table l _5 . Therefore, based on the similarity in operating ranges of these
incinerators, and since the incinerators treating 1(015, 1(086, and F024 have
been shown to provide substantial treatment of hazardous organic constituents,
EPA expects that incineration systems with similar operating conditions, also
provide substantial treatment for 1(027, 1(113—1(116, U221, and U223.
1(027, 1(111—1(116 BD—3 B—12
1207—01 .nrj.12
------- |