Impact of the
Resource Conservation and
Recovery Act
on
FBC Residue Disposal
May 1980
VJestingUouse R&D Center
1310 Beulah Road
Pittsburgh, Pennsylvania 15235
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IMPACT OF THE RESOURCE CONSERVATION AND RECOVERY ACT
ON
FBC RESIDUE DISPOSAL
by
C. C. Sun
R. A. Newby
D. L. Kealrns
Westinghouse Research and Development Center
1310 Beulah Road
Pittsburgh, PA 15235
Contract No. 68-02-3110
EPA Project Officer: D. Bruce Henschel
Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, NC 27711
May 1980
Prepared for
U. S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, DC 20460
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PREFACE
The Westinghouse R&D Center is carrying out a program to
provide experimental and engineering support for the development of
fluid ized-bed combustion systems under contract to the Industrial
Environmental Research Laboratory (IERL), U. S. Environmental Protection
Agency (EPA), at Research Triangle Park, NC. The contract scope includes
atmospheric (AFBC) and pressurized (PFBC) fluidized-bed combustion
processes as they may be applied for steam generation, electric power
generation, or process heat. Specific tasks include work on calcium-
based sulfur removal systems (e.g., sorption kinetics, regeneration,
attrition, modeling), alternative sulfur sorbents, nitrogen oxide (NO^)
emissions, particulate emissions and control, trace element emissions
and control, spent sorbent and ash disposal, and systems evaluation
(e.g., impact of new source performance standards (NSPS) on FBC system
design and cost).
This report on the impact of RCRA contains the results of work
defined and completed as part of the spent sorbent and ash disposal
task of the contract. Work on this specific task was performed from
January 1979 to March 1980. Related documentation is found in the
following reports:
• "Disposal of Solid Residue from Fluidized-Bed Combustion:
Engineering and Laboratory Studies," EPA-600/7-78-049
(NTIS PB 283-082), issued in March 1978, which presented
the results of work performed from January 1976 to
January 1977
• "Experimental/Engineering Support for EPA's FBC Program;
Final Report, Vol. Ill, Solid Residue Studies,
£PA~600/7-80-015e, issued in January 1980. The report
documents work performed from January 1977 to January 1979
i 111
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and subsequent extensions from review of the draft
through October 1979.
Since proper disposal of solid residue is of primary importance
to the commercialization of the FBC process, continuing effort is directed
toward solid residue studies under the current Westinghouse contract to
EPA (68-02-3110).
Work on the other tasks performed under this contract has
also been reported:
¦ Experimental/Engineering Support for EPA's FBC Program:
Final Report Volume 1, Sulfur Oxide Control, EPA-600/7-80-0l5a,
January 1980.
• Experimental/Engineering Support for EPA's FBC Program:
Final Report Volume II, Particulate, Nitrogen Oxide, and
Trace Element Control, EPA-600/7-80-015b, January 1980.
• Experimental/Engineering Support for EPA's FBC Program:
Final Report Volume IV, Engineering Studies, EPA-600/7-80~015d,
January 1980.
• Effect of SO^ Emission Requirements on Fluidized-Bed
Combustion Systems: Preliminary Technical/Economic
Assessment, EPA-600/7-78-163, August 1978.
• Regeneration of Calcium-Based SO^ Sorbents for Fluidized-
Bed Combustion: Engineering Evaluation, EPA-600/7-78-039,
NTIS PB 281-317, March 1978.
• Alternatives to Calcium-Based S02 Sorbents for Fluidized-
Bed Combustion: Conceptual Evaluation, EPA-600/7-78-005,
January 1978.
• Evaluation of Trace Element Release from Fluidized-Bed
Combustion Systems, EPA-600/7-78-050, NTIS PB 281-321,
March 1978.
iv
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ABSTRACT
The Resource Conservation and Recovery Act of 1976 (RCRA) created a
new level of regulatory control of solid waste disposal. The emphasis
of the act is on identifying hazardous wastes, regulating hazardous
waste from cradle to grave (RCRA Subtitle C), and improving nonhazardous
waste disposal practices (Subtitle D). The fluidi^ed-bed combustion
(FBC) process for electric power generation produces large quantities of
residue (spent sorbent and ash) which are subject to RCRA control. The
key provisions of RCRA that have the greatest impact on FBC residue
disposal are Subtitles C and D. This report provides an assessment of
RCRA and its current regulations with respect to FBC residue disposal
and, of special importance, the proposed Sec. 3001 regulations for
hazardous waste identification. RCRA tests, in particular the Sec. 3001
extraction procedure (EP), were performed on a variety of FBC residues
representing several process variations. Results indicate that FBC res-
idue is nonhazardous. The impact of RCRA regulations and criteria pro-
posed prior to promulgation on May 19, 1980 on FBC residue disposal is
assessed.
v
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TABLE OF CONTENTS
Page
ABSTRACT
ACKNOWLEDGMENT
1. SUMMARY/CONCLUSIONS i
Impact of Hazardous Waste Identification Criteria on the
Classification of FBC Residue Disposal (Subtitle C) 1
Impact of Nonhazardous Waste Disposal Regulations on FBC
Residue Disposal (Subtitle D) 4
Impact of RCRA on Siting of FBC Facilities 5
Impact on FBC Economics 5
2. RECOMMENDATIONS 7
Uazardous/Nonhazardous Waste Identification 7
FBC Disposal Practice g
3. INTRODUCTION 9
4. FLUIDIZED-BED COMBUSTION PROCESS n
Sources of FBC Residue H
Solid Waste Disposal Rates 13
Review of FBC Residue Studies 14
5. RESOURCE CONSERVATION AND RECOVERY ACT 20
Overview 20
Key Sections of RCRA 21
Hazardous Waste Management 21
Nonhazardous Waste Disposal 26
Integration with Other Legislation 28
vii
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TABLE OF CONTENTS (Cont'd)
Page
6. EXPERIMENTAL CRITERIA AND RESULTS 30
Hazardous Waste Identification Criteria 30
Ignitability 30
Corrasivity 30
Reactivity 32
Toxicity 32
Hazardous Waste Identification Tests 32
Extraction Procedure Test Development 32
Samples 35
Procedures and Equipment 37
Results acid Discussion 38
Nonhazardous Waste Disposal Criteria and Results 40
7. ASSESSMENT OF RCRA IMPACT ON FBC RESIDUE DISPOSAL 47
Impact of Nonhazardous Waste Disposal Regulations on FBC
Residue Disposal (Subtitle D) 47
Impact of Hazardous Waste Disposal Regulations on FBC
Residue Disposal (Subtitle C) 48
Impact of RCRA on Fossil-Fuel Energy Facilities 52
Impact of RCRA on Utility Solid Waste 52
Impact of RCRA on Siting of Fossil-Fuel Energy Facility 53
Itnpact o£ RCRA on FBC Economics
8. REFERENCES 56
APPENDICES
A. Assessment of RCRA/TEP on FBC Residue Part I - EPA
Draft Procedure of March 1978
61
B. EPA Interim Primary and Secondary linking Water Standards 75
C. Chemical Characterization of Residue Samples 76
D. RCRA/Extraction Procedure (43 FR 58956)
viii
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LIST OF FIGURES
Page
1. Flutdized-Bed Combustion General Solid Flow Diagram 12
2. Effect of Sorbent Activity Category and Particle Size
on Ca/S Molar Feed Ratio Requirement 15
3. Solid Waste Production for Eastern Coal - 90% Sulfur
Removal 15
4. Solid Waste Production for Western Coal - 70/2 Sulfur
Removal ^7
5. Hazardous Waste Identification Mechanism 23
6. Effect of Sorbent Cost on the Economics of AFBC and
PFBC Systems 55
ix
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LIST OF TABLES
1. Total Waste Solids with 500 pm Average Bed Particle
Diameter [5
2. Definition of the Characteristics of a Hazardous Waste 3 I
3. RCRA 3U01 Regulation Development 3]
4. Development of EPA Leach Test 34
5. Summary of F3C Samples Tested Using RCRA/TEP and
RCRA/EP 36
6. Leachate Characteristics (Trace Elements) from
RCRA/EP Test 39
7. Leachate Characteristics (Major Species) from
RCRA/EP Test 4i
8. Hazardous Waste Criteria (RCRA Section 300L) 42
9. Comparison of a Typical F8C Leachate with the DWS 44
10. Toxicity of EP Extracts from Fossil-Fuel Process
Residues by ORNL 51
x
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NOMENCLATURE
AFBC
-
atmospheric-pressure fluidized-bed combustion
AMP R
-
Advance Notice of Proposed Rulemaking
C A A
-
Clean Air Act
C BC
-
carbon burnup cell
CWA
-
Clean Water Act
DOE
-
Department of Energy
DWS
-
drinking water standard
EP
-
extraction procedure
EPA
-
Environmental Protection Agency
FBC
-
fluidized-bed combustion
FCD
-
flue-gas desulfurination
11W1
-
Hazardous Waste Management program
NEPA
-
National Environmental Policy Act
NIPDWR
-
National Interim Primary Drinking Water Regulations
NPUES
-
National Pollution Discharge Elimination System
NSDWR
-
National Secondary Drinking Water Regulations
NSPS
-
New Source Performance Standard
ORNL
-
Oak Ridge National Laboratory, Oak Ridge, TN
OSHA
-
Occupational Safety and Health Act
OSU
-
Office of Solid Waste
PCR
-
polychlorlnated biphenyl
PFBC
-
pressurlEed fluidized-bed combustion
PSD
-
Prevention of Significant Deterioration Program
RCRA
-
Resource Conservation and Recovery Act
SIT
-
Structural Integrity Test
TDS
-
total dissolved solids
TEP
-
toxic extraction procedure
TO C
-
total organic carbon
TSCA
-
Toxic Substances Control Act
UIC
-
Underground Injection Control program
xi
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ACKNOWLEDGMENT
This rfork was performed under Cont rar.t 68-02-3110 for the Indus-
trial and Envi ronmental Research Laboratory of the 11. S. Envi ronmontal
Protection Agency. We would like to acknowledge the cont ribut i oris of
D. 8» Hensehel in his function as project officer.
Our special thanks go to J. T. McAdams for his technical assistance
in carrying out the laboratory experiments. We should, also like to
express our appreciation to rcany members of tlie Analytical Chemistry and
Biology Departments within the Westinghouse Research and Development
Center for their valuable contributions in sample characterization.
xii
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1. SUMMARY/CONCLUSIONS
In the fall of 1976, President Ford signed Into law P.L. 94-580,
the Resource Conservation and Recovery Act (RCRA),* which attempts to
close the circle of environmental regulation by controlling those sub-
stances that pose a threat to human well-being or to the environment but
that were not covered by the earlier laws governing air and water pollu-
tion.. Despite its name,the thrust of the act is on creating a compre-
hensive scheme for regulating hazardous waste (Subtitle C - Hazardous
Waste Management) and for improving solid waste disposal practices (Sub-
title D - State and Regional Solid Waste Plans). Regulations proposed
under RCRA Sec. 3001 or Subtitle C on identification of hazardous wastes
in the Federal Register, December 18, 19782 received special emphasis.
The fluidized-bed combustion (FBC) process for electric power gen-
eration produces solid wastes that fall under the jurisdiction of RCRA.
The purpose of this report is to determine if FBC residues are hazard-
ous, according to RCRA procedures as proposed in December 1978, and to
assess the impact of RCRA and the RCRA regulations (promulgated or pro-
posed prior to the completion of this report in April 1980) on FBC resi-
due disposal.
The key provisions of RCRA that could have the greatest impact on
FBC residue disposal are Subtitle C on hazardous waste management, in
particular the hazardous waste identification criteria under Sec. 3001,
and Subtitle D,which regulates disposal of nonhazardous waste.
IMPACT OF HAZARDOUS WASTE IDENTIFICATION CRITERIA ON THE CLASSIFICATION
OF FBC RESIDUE (Subtitle C)
RCRA Sec. 3001 of Subtitle C requires EPA - Office of Solid Waste
(OSW) to promulgate criteria for identification of hazardous waste,
which OSW began to develop in 1977. In March of 1978, a first draft
1
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was released which contained tentative hazardous [dent i fteat i on incth-
o ds. A toxic extraction procedure (TKP) was drafted to determine the
toxicity of a waste. Those wastes whose TKP 1 oaehate had 10 times the
National Interim Primary Drinking Water Regulations (If) x MFl'DWR) would
he considered hazardous. Public, comments we re requested on the d ra f t
regulations. We responded by testing typical KBC residues and reference
materials (raw sorbent and conventional FfID residue). Results of our
TKP testing and recommendations on the TKP p roe. edit re were comma 11 i ca ted
to EPA in 19 78 (Appendix A).
On December 18, 1978, KPA formally proposed in the Federal
Register*- RCRA Sec. 1001 regulations which were scheduled to he promul-
gated in April 1980, following completion of this report. In that pro-
posal the TKP was significantly modified on the basis (if the additional
informat ion supplied by public comments (including our recommendations)
and was renamed the "extraction procedure" (KP) with 10 x NIPDWR of
heavy metal elements as the hazardous criteria. According to proposed
Sec. 3001, a waste can be classified as hazardous either by being on the
hazardous lists (proposed by EPA on December 18, 1978 and August 22,
"7 /
1979)^>4 or by possessing any of the proposed hazardous characteristics.
The FBC residue is not on the hazardous lists, and, therefore, Its clas-
sification must be determined from the proposed criteria for hazardous
characteristics - ignitability, corrosivity, reactivity, and toxicity.
Of the four characteristics, toxicity, for which EPA has proposed an
extraction procedure (EP) and hazardous criteria (10 x NIPDWR), causes
the most concern for FBC residue. Because of the potentially large
volume of residues from various Industrial sources and the limited data
on their potential hazard, EPA has proposed a list of "special wastes"
under Sec. 3004; "utility waste" is among these five special wastes.
Should FBC waste be deemed hazardous according to Sec. 3001, we expect
it would be classified as a utility waste under the special waste
category and would be regulated with partial exemption from the cradle-
to-grave regulations under hazardous waste management Sec. 3002 to 300r).
2
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On Che other hand, should FBC waste be identified as nonhaza rdotis, it
would fall under the jurisdiction of Subtitle D and its disposal would
then be regulated as a sanitary landfill waste.
FMC residue is not ignitable, corrosive, or reactive according to
the proposed criteria. To determine if it is toxic, 17 FBC residues
representing several process variations, [atmospheric (AFRC) and pres-
surized (PFBC) fInidized-bed boilers/PFBC adiabatic conbustor,
bed/carry-over, with/without carbon bnrnup cell (CBC), once-through/
regenerative operation, limestone/dolomite sorbents] together with ref-
erence materials (FGD residues, conventional ash, and raw sorbent) were
tested using the former TEP and the proposed EP tests. Results that
showed the EP leachates to have silver (Ag), arsenic (As), barium (Ba),
cadmium (Cd), chromium (Cr) , mercury (Ilg), lead (Pb) and selenium (Se)
below 10 x NIPDWR indicated the FBC residue to be nontoxic and, thus,
nonhazardotis. The only exception among the EP leachates of 17 FBC resi-
dues was the leachate from an Exxon PFBC run with sorbent regeneration,
which had an average arsenic concentration of 0.94 ppm (compared to the
criterion of 0.5 ppm). A.FBC and PFBC fines (<15 Mm) from the third-
stage cyclone and bag filter and PFBC regenerator bed material had
chromium concentrations in their EP leachates (0.15 to 0.4 ppm) much
higher than the others (<0.l ppm) and were close to the criterion for
chromium, 0.5 ppm. Future investigations, therefore, should emphasize
samples from these sources.
We assumed that the FBC residues would not contain chlorinated
organic pesticides and herbicides and, thus, did not perform EP analyses
for Lindane, Methoxychlor, Toxaphene, or 2.4-D and 2.4.5-TP Silvex,
which were also proposed in Sec. 3001.
Bioassays and testing for radioactivity were not included in the
proposed identification methods for hazardous characteristics (ignit-
ability, corrosivity, reactivity, and toxicity) and thus were not
3
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carried out In our investigation on FBC residues. However, EPA is eon-
s i--If? ring expand i.ng the hazardous characteristics to include radt oaot iv-
i ty, genetic activity, bioaccumul.at ion, and addition;)] aspects of tonic-
ity (Advanced Notice for Proposed Ru1enaking, federal Register, Decem-
ber 18, 1978).- Oak Ridge National 7,aboratory (ORML)5*^ conducted bio-
assays on fossil fuel residues undo r DOE and EPA contracts and reported
that FBC residue sliowed negative results in mutagenicity, in aquatic and
phytotoxicity, anil in metal elements, agreeing with our conclusion Lhat
the FBC residue is nonhazardous. ASTM DI9.12^ also carried out bioassay
tests; results are less conclusive din; to difficulties encountered in
sample preparation test procedures and interpretation of test results.
IMPACT OF NONHAZARDOUS WASTE DISPOSAL REGULATIONS ON FBC RESIDUE
DISPOSAL (SUBTITLE D)
According to the current regulations promulgated on September 13,
1979,^ eight criteria, including site selection and leac.hate monitoring,
apply to the nonhazardous solid waste sanitary landfills, where FBC
waste would most likely be disposed of. The most important Issues that
can affect the FBC residue disposal, however, are the standards for
ground- and surface water. Compliance with RCRA and the National Pollu-
tion Discharge Elimination System (NPDES) under the Clean Water Act
(CWA)9 is required of a sanitary landfill. Efforts by EPA are under way
to consolidate the solid waste permit system. Since effluent guidelines
for FBC units and FBC residue disposal facilities are currently unavail-
able, engineering judgment must be applied for designing, operating, and
managing the disposal facility to avoid potential adverse environmental
effects. Because FBC leachates meet the primary DWS,which consists of
eight heavy metals, fluoride (F), and NO3, FBC residue disposal Is
expected to meet the current standards for sanitary landfill : ground-
water at the "disposal facility boundary" must satisfy the primary
drinking water standards (NIPDWR). Should the secondary DWS (NSDWR) be
U
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included as they are cur rvutly proposed (Federal Register, September 13,
1979),^ however, FBC loni-hate pH would he a major concern,as the pH of a
typical FBC leachate ranges from 9 to 12 while the pH of NSDWR ranges
from 6.5 to 8.5. Total dissolved solids (TDS) and sulfate (SO^) are of
passing values if a ten times attenuation/dilution factor is assumed.
As soil attenuation and dilution can play a major role in reducing
leachate pH, TDS, SO4, and calcium, site selection and disposal facility
design are critical factors in controlling potential groundwater contam-
ination. In addition, contamination of groundwater due to those trace
metal elements and the microbiological activity included in the DWS is
not expected because FBC test leachates meet both the NIPDWR and the
secondary drinking water regulations (NSDWR). Radioactivity, if any,
should be similar to that of a conventional power plant residue.
IMPACT OF RCRA ON SITING OF FBC FACILITIES
The key aspects of RCRA that would affect the siting of new FBC
facilities are provisions for hazardous and solid waste disposal (Sub-
titles C and D) and provisions for resource recovery (Subtitle E). The
increased costs of transportation and disposal of the waste brought on
by RCRA,as well as the marketability and transportation costs of FBC
waste products (should FBC residue be utIl lzed), wi.l 1 play an Important
role In siting FBC facilities. Also, in light of the public, awareness
created by RCRA, public support or opposition is becoming increasingly
important in determining sites for fossil-fuel energy facilities.
IMPACT ON FBC ECONOMICS
The economics of FBC systems are sensitive to the total cost of
sorbent, Including purchase, transportation, and disposal. The major
increase In disposal costs resulting from RCRA are expected to be asso-
ciated with disposal site selection, site operation, and solid residue
transportation. The sensitivity of FBC economics to total sorbent cost
may lead FBC developers to consider more seriously alternatives for
5
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reducing the total amount of sorbent consumed or methods to reduce dis-
posal cost,such as residue processing or ut i 1 i/.at ion, if the expect ml
increase in the cost of solid waste disposal resulting f row RCRA is sig-
nificant. The technical and cost effects of KCRA on I' !iC res i due dis-
posal are such that they mu s t be incorporated in the development of the
Integrated FttC system.
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2. RECOMMENDATIONS
This report presents an assessment of the effect of RGEIA on FBC
residue disposal, based on current regulations, some of which were pro-
posed bat not promulgated until this study was completed. We. there-
fore, recommend close review of RCRA development and updating its
impact as new rules and amendments come Into existence,with specific
attention to the issues that follow.
HAZARDOUS/NONUAZARDOUS WASTE IDENTIFICATION
This investigation was based on the proposed RCRA Subtitle C regu-
lations in the Federal Register of December 18, 1978,2 particular
Sec. 3001, hazardous waste identification. Changes in the following may
have an additional impact on FBC residue disposal, and reassessment may
be required :
• EP test and leachate criteria
• Corrosivity/pH criteria
• Reactivity criteria with respect to exothermic hydration of
CaO and CaS/concentration
• Bioassays, radioactivity testing methods, and interpreta-
tion. Although currently not a requirement, FBC residues
should be investigated for radioactivity and genetic
effects, both in terms of legislative requirement and in
terms of better understanding of the potential hazard from
a technical point of view.
• Approach to identifying hazardous waste - single test ver-
sus multistage screening.
7
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In addition, chromium and arsenic in Che leaeliate fru-a 1'IJC carry-
over flues (<15 pin) and from Llie residue re.sul t Lny f r»m n;;;L- in- ra L I v e
raas should be closely examined in future investigations to confirm
t he: i r cIassi.ficati.on as nuiihaza nioa.s.
FBC DISPOSAL PRACTICE
Based on this Investigation, KBC residue is nonhazardous and,
therefore, wiLI be disposed of in a sanitary land til I. Regulations and
disposal criteria for sanitary landfills under the RCRA Sees. 4004 and
10o8 and tile CWA will determine FiiC disposaL practice.
Since the groundwater criteria are applicable at the "disposal
facility boundary," which will incorporate, effects of soil attenuation
and dilution, these effects should he investigated further. These
effects are especially important with respect to teachate pll, IDS, SI)/,
and calcium should the secondary DWS be included as part of the ground-
water criteria in the future. Control technologies for major leaehare
variables, i.e., pll, TDS, SO^, and calcium, should be evaluated in the
event that dilution/attenua t. ion effects might not be sufficient for some
specific sites.
Other aspects of disposal, such as the proper procedures fur han-
dling the FBC residue, disposal site selection, facility design, con-
struction, operation, and management need to be investigated. Engineer-
ing and economic evaluations of FBC waste disposal should be carried
out, incorporating RCRA requirements as part of an integrated effort to
develop commercial FBC systems.
8
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3. t NT RODUCT LON
With the enactment of the National Rnvironmental Policy Act of 1969
(.VEPA), we are charged with a "responsibility to contribute to the pres-
ervation and enhancement of the environment." Efforts to protect the
environment have led us to recognize the interplay of the components of
our physical environment --air, water, and land.
Historically, the first important piece of Legislation passed after
NliPA was the Clean Air Act of 197Q (CAA) , amended again in 1977, 10 which
set forth the mechanisms for establishing national ambient air quality
standards and new source performance standards (NSPS). To meet these
standards Industries employed air pollution control devices, such as
scrubbers, that could control emissions to the air but would also leave
residue that could contaminate surface and groundwater if not carefully
controlled.
In October 1972, Congress passed another piece of legislation, the
Federal Water Pollution Control Act, amended in 1977 as the Clean Water
Act (CWA),9 to restore and maintain the chemical, physical, and biologi-
cal integrity of the nation's waters. This act prohibited discharge of
toxic pollutants in toxic amounts. As a result of the Clean Air Act,
the Water Pollution Control Act, and other federal and state laws
respecting public health and the environment, greater amounts of solid
waste in the form of sludge and other pollution treatment residues have
been created. Similarly, inadequate and environmentally unsound prac-
tices for the disposal or use of solid waste have created greater
amounts of air and water pollution and other problems for the environ-
ment and for health.
In the fall of 1976, President Ford signed into law PL 94-580, the
Resource Conservation and Recovery Act of 1976 (RCRA),which represented
9
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a substantial, amendment of the Solid Waste Disposal Act of 19brj (as
amended previously by the Resource Recovery Act of 1970).^ The passage
of RCRA created a federal and state regulatory authority over solid and
hazardous waste. In essence the act attempts to close the circLe of
environmental regulation by control ling those subsLances that pose a
threat to human well-being or the environment but that were not covered
by earlier laws governing air and water pollution. Despite its name,
the main thrust of the RCRA is neither resource conservation nor
recovery. Although the Act does deal with these topics, It concentrates
on creating a comprehensive scheme for regulating hazardous wastes and
for improving solid waste disposal practices.
The fluidized-bed combustion (FBC) process for electric power gen-
eration produces solid wastes that falL under the jurisdiction of RCRA.
The purpose of this report is to provide data based on proposed RCRA
tests on a variety of FBC residues and to assess the impact of RCRA and
its regulations on FBC residue disposal. The report identifies probable
classification of FBC solid waste and applicable standards for their
disposal. The potential impact on plant design and cost is mentioned
but is not within the scope of this study. We have particularly empha-
sized regulations proposed under RCRA Sec. 3001 for the identification
of hazardous wastes. To determine if FBC residues are hazardous we car-
ried out an experimental program based on the proposed extraction proce-
dure (EP). In addition, in assessing the impact of RCRA on FBC solids
disposal we have reviewed related work reported by other investigators
to supplement our own experimental results.
Since RCRA has been, only recently enacted, however, and its guide-
lines are still in the developmental stage, the assessment of the impact
of RCRA on FBC residue disposal presented in this report will require
periodic updating as the proposed regulations are promulgated or modi-
fied and as new rules are implemented.
10
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4. THK KL(I [ l) tZKD-COMBUST LON PROCESS
Fluidized-bod combustion is an emerging technology that is being
developed to utilize coal in an environmentally acceptable manner.
Fluidized-bed combustion processus, operated at .atmospheric (AFBC) or at
elevated (PFBC) pressure, employ limestone or dolomite to remove sulfur
-------
Dwg. 7718a!3
fFlue Gas
Acid
kGas
V
Sorbent
Coal
*
Fluid-Bed
Combustor
Carryover-.
Sorbent Fines and Ash
to Disposal/Processing
Utilized
Sorbent
¦>
Regenerated
Sorbent
V
General
Regeneration
Process
Carryover.-
* Sorbent Fines and
Ash, to Disposal/
Processing
Spent Bed Material,
to Disposal/Processing
Figure 1. Fluidized-Bed Combustion General Solid Flow Diagram
-------
combustor, having the hulk bed characteristics, and the fines-particle
stream -withdrawn from the part Loulate control system.
Figure 1 also shows an FBC system with sorbent regeneration. The
regenerated sorbent is recycled to the combustor. The solid waste is
represented by the stream withdrawn from either the combustor or the
regenerator bulk beds, plus the fine material withdrawn from the combus-
tor and regenerator particulate control systems. Sorbent regeneration
has not reached the same stage of development as has once-through opera-
tion. Several feasibility questions remain unanswered. Several other
KBC process variations are possible. The actual .samples investigated in
this study and their sources will be discussed in Section 6.
SOLID WASTE IHSPOSAL RATES
The following factors can significantly influence the characteris-
tics of the solid waste produced by FBC systems:^
• Coal properties - sulfur content, heating value, and ash
content
• Fresh sorbent properties - type of sorbent (limestone or
dolomite), composition, physical structure, and attrition
behavior
• Fluid-bed combustion system concept - power cycle
(atmospheric-pressure boiler, pressurized boiler, adl-
abatic combustor), fluid-bed mode (bubbling, fast flu-
id! zed, multisolids, etc.), particulate control system,
fines recycle
• Fluid-bed combustor design and operating conditions - tem-
perature, pressure, excess air, residence times of sorbent
and gas, Ca/S feed ratio, superficial velocity, coal and
sorbent feed size, coal and sorbent feeding, internals
design, distributor design, turndown operating conditions,
and so forth.
13
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• Sulfur removal system - onee-through, sorbent pret r.¦.i;at nt
(precalculation, salt exposu re , thermal exposure, i ¦ t: < ¦. ) ,
sorbent r-jae.t i va t ion (hyd rat i on, a,t;;;lome ration) , sorbent
regene ra L Lon.
The range of quantity of solid waste produced by l'!iC proo'ssi's is
ver.' broad. The mass fraction of ash in coal may range between D.02 and
0.30 for U.S. coals. Figure 2 shows ho..; sorbent activity and s i
a f fact sulfur removal performance for onee-through AlrKC. l/+ The result-
ing 'iis.s ratio of ash to waste sorbent calc i un may range- between about
0.1 and 200 for onco-th rough oporat Lon. For regenerat i. ve ope rat ion Ca/S
rjav ra nge between 0.2 and 2.0, and the ash/sorbent ratio may range
between about 0.15 and 110, a range not much different from the once-
through case.
Table 1 shows total solid waste produced in a once-through, A KIM.'
system as a function of the sorbent activity category, the required sul-
fur removal efficiency, and the type of coal. These values would hi'
representative of both electrical utility and industrial oporat ions. '
Predicted solid waste rates for advanced sulfur removal systems are
shown in Figures 3 and 4 and compared with once-through operation. For
eastern coals, Figure 3, a significant reduction in solid waste can he
realized by an advanced system, while for western coal, Figure 4, the
reduction is negligible. Process variations such as these must be con-
sidered in assessing the impact of RCRA on FBC.
REVIEW OF FBC RFSIHUH STUDLHS
Since 1969, Westinghouse has been providing engineering and experi-
mental support of the development of the FBC processes. Fluidized-bed
combustion solid residue studies, which include characterization,
14
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100
ro
>
O
E
90
-------
< h i 1/, ¦ /1 i r i _
1.0
0.8
0.6
0.4
0. 2
1.0
0.8
0.6
0.4
0.2
1.0
0.8
0.6
0.4
0.2
^ ¦
-A.
Tymochtee Dolomite
Lime Scrubber Sludg^
//V
Grove Limestone
Lime Scrubber Sludge*
%
\V
\\
\\
'^//z
/^y
v//,
Greer Limestone
Lime Scrubber Sludge"1
~7~A
JZ
en
i ^
s e
= JZ
O i—
tz
o
a>
c
3 E
f- VI
^ 4- O ro
<03 o rl x ro ^
v- "jz co a> ll
a. m W UJ T h-
a>
E
° c
cn O
arj:
1
x: IT "
i— a>
• c oc
ID (D _
£> c g"5
CZ O C£ IS)
a>
c
a)
Figure 3 - Solid Waste Production for Eastern Coal -
90% Sulfur Removal (*Wet Basts)^
16
-------
Curve /I
0.08
0.06
0.04
0.02
0.10
0,08
0.06
0.04
0.02
7 / /
/.-<
/./
Tymochtee Dolomite
Grove Limestone
Greer Limestone
o — ft) 55
CL m 00 lQ 3! 1—
Figure k - Solid Waste Production for Western Coal 70%
Sulfur Removal1^
17
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disposal, and farther processing of the solids, have been discussed
extensively in our previous reports. • To provide background infor-
mation on the disposal of FBC residue, we have condensed conclusions
f con the previous studies, which were based on a cornpn-hens I ve test pro-
gram on a variety of FBC residues:
« Major concerns for FBC residue disposal are the high pH,
TDS (total dissolved sol ids), calcium, and sulfate levels
(SO4) in the leaehate; the thermal activity; and the
large quantity of solid to be disposed of.
• Trace metal element levels in FI5C leaehate are low. \Jith
only two exceptions (one AFHC bagfilter sample and one
PFliC third cyclone catch), leachates of all FBC residues
(>40 samples) tested throughout this and previous studios
met all the existing drinking water standards (DWS) for
heavy metals.
• The total organic carbon (TOC) level in FBC leachates is
low. All (>40 samples) except one (TOC = 30 ppm for
leaehate of an AFBC bagfilter sample) were below or near
the detection level (<10 ppm).
• Trace elements are more concentrated in the carry-over and
in its leaehate than in that of bed material. The spent
bed material, on the other hand, consists predominantly of
spent sorbent, and, therefore, its leaehate has higher pH,
calcium, SO4, and TDS levels.
• Leaching property is a function of leaehate pH. In gen-
eral, higher levels of trace metal elements exist in
leachates having a lower pH.
• The pH, calcium, and TDS levels of an FBC leaehate depend
largely on the amount of unutilized CaO present in the
solid. Higher pH, calcium, and TDS levels are found in
the leachates of residues with lower CaO utilization. On
18
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the average, the leachate of AKIiC residue has a higher pH,
calcium, and TOS level, than ihat of PFBC residue, which
generally contains less CaO. Similarly, the leac.hate of
spent limestone sorbent contains higher concentrations of
calcium, TOS, and pll than that: of spent dolomite.
• Substantial heat is released from AFRC residue upon its
initial contact with water and nay require special han-
dling and disposal procedures to minimize this thermal
ac t ivi ty.
• The thermal activity is largely dependent on the amount of
CaO present in the residue and is also a function of the
rliC operating conditions, which may result in either cal-
cined or uncalcined sorbent in the form of CaO or CaCC^.
Thus, thermal activity is higher for the AFRC than for the
PFBC residue and higher in bed material than in carry-
over.
• Processing FBC residue can effectively reduce thermal
activity and lower the permeability of the solid to be
disposed of, thus minimizing potential leachate
contamination.
• Although an absolute comparison may not be possible, gen-
eral trends have shown that the physical, chemical, and
leaching properties of FBC residue are superior to the
nonstabilized FGD sludge with regard to disposal and are
comparable to the chemically and physically stabilized FGD
residue from a conventional power plant.^
On the basis of our findings, we have concluded that residue dis-
posal may not be an obstacle in the commercialization of the FBC pro-
cess, but further Investigation is required. The next few sections of
this report provide an assessment of RCRA and RCRA regulations on FBC
residue disposal.
19
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5. RFSOURCK CONSERVATION AND RECOVERY AC I'
' 'VERVIEW
The Resource Conservation and Recovery Act' is romp rvhriv;i v, with
mine rous provisions aimed at the t'nvi romne ntal 1 y safe disposal of solid
waste and the recovery of resources From these wastes. The art greai 1y
expands the role of the federal government in tin1 field of solid waste
management, with particular emphasis on creating a major now federal
hazardous waste regulatory program while ene.oiirat'i ng state and regional
solid waste planning. The act is divided into eight subtitles:
• Subtitle A - Ceneral Provisions
• Subtitle B - Office of Solid Waste; Authorities of the
Ad mi n i s t ra tor
• Subtitle C - Hazardous Waste Management
• Subtitle D - State or Regional Solid Waste Plans
• Subtitle E - Duties of the Secretary of Commerce in
Resource and Recovery•
• Subtitle F - Federal Responsibilities
• Subtitle G - Miscellaneous Provisions
• Subtitle H - Research, Development, Demonstration, and
Information.
According to the definition in Sec. 1004(27) in Subtitle A, the
term "solid waste" moans "any garbage, refuse, sludge from a waste
treatment plant, water supply treatment plant or air pollution control
facility and other discarded material, including solid, liquid, semi-
solid, or contained gaseous material resulting from industrial, commer-
cial, mining and agriculture activities and from community activi-
ties...." The definition is broad and includes all solid and liquid
wastes. Subtitle B is important in that it establishes the "Office of
20
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Solid Waste" (OSW) within EPA and authorises it to implement RCRA. The
key sect, ions tlvit could af fact FBC residues, however, are Subtitles C
and D on hazardous and nonhazardous waste management.
KF.Y SECTIONS OF RCRA
Hazardous Waste Management
According to the definition provided in RCRA Sec. 1004(5), the terra
"hazardous waste" is
A solid waste, or combination of solid wastes, which because of
its quantity, concentration, or physical, chemical, or infectious
characteristics may —
(a) Cause, or significantly contribute to an increase in mor-
tality or an increase In serious irreversible, or Incapac-
itating reversible, illness; or
(b) Pose a substantial present or potential hazard to human
health or the environment when Improperly treated, stored,
transported, or disposed of, or otherwise managed.
Subtitle C - Hazardous Waste Management - establishes a federal
program to provide comprehensive regulation of hazardous waste. When
fully implemented, this program will provide cradle-to-grave regulation
of hazardous wastes. It contains the following sections:
Sec. 3001 - Identification and Listing of Hazardous Waste
Sec. 3002 - Standards Applicable to Generators of Hazardous Waste
Sec. 3003 - Standards Applicable to Transporters of Hazardous
Waste
Sec. 3004 - Standards Applicable to Owners and Operators of Hazar-
dous Waste Treatment, Storage and Disposal Facilities
Sec. 3005 - Permits for Treatment, Storage, or Disposal of Hazar-
dous Waste
Sec. 3006 - Authorised State Hazardous Waste Programs
Sec. 3007 - Inspections
Sec. 3008 - Federal Enforcement
21
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Sec. "3009 - Retention of State Authority
Sec. 1010 - Effective Date
See. 3011 - Authorisation of Assistance to States.
Section 3001 requires P.PA - OSW to promulgate criteria for identl-
fieation of hazardous waste, which OSW has been do ve 1 op i ng since 1977. I 7
In March 1078, a draft eontai n ing tentative hazardous waste i dent i. f I na-
tion methods was released.^ A procedure for de to nni n i ng the toxicity of
a waste - toxic extraction procedure (TKP) - was drafted. [f its TKP
leachate exceeded ten times the Nat tonal interim P r i ,na ry !) r i .lk i ag Water
Regulations (NIPDWR) the waste would ho considered toxic.
Public comments on the draft regulations were sol i r i te<|. 'Nesting-
house responded by testing typical KBC residues and reference aaf.e rials
(raw sorbent and conventional PCI) residue) and comimmi ca t i ng I 'ie r.'sul ts
of TEP testing and our recommendations on TKP procedure to EPA
(Appendix A).
On December 13, 1978, KPA formally proposed in the Federal
Register^ RCRA Sec. 3001 regulations, scheduled for promulgation in
April 1980. The TEP was significantly modified on the basis of addi-
tional information supplied by the public comments (including the West-
inghouse recommendations) and was renamed "extraction procedure" (HP).
The criterion for hazardous waste was the KP Leachate containing higher
than 10 x NIPDWR of heavy metal elements, toxic organic herbicides, and
pesticides. Extraction procedure testing of FBC residues and reference
materials is presented in Section 6. According to the proposed regula-
tions, a waste can be classified as hazardous through either one of the
two routes presented In Figure "3 :
• By being on the hazardous waste list proposed in the _Fed-
eral Register, December 18, 1978^ and August 22, 1979^ and
based on waste sources and processes (at the right of
Figure 5)
22
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Hazardous waste
Lists
Not on Lists
Listed Wastes
Radioactive
Toxic
Organic
Fail Any
Pass All
Fail Any
Pass All
Reactive
Corrosive
Toxic
Corrosive
Reactive
Toxic
Bioaccuma-
lative
Mutagenic
Infectious
Hazardous
Waste
Hazardous
Waste
EP Test
<10 x DWS)
Non-Hazardous
Waste
Non-Hazardous
Waste
Hazardous Waste Characteristics
Non-Inclusion Tests
Solid Waste
Figure 5. Hazardous Waste Identification Mechanism
-------
• By riot b<* i. nj; on the list: but by |)os::c;:; i nj; oiif ,,r -x , n*
ha/, a r characterise. i cs ( lp.nl tabll11 y, n»r r>>^. i / i t >.>,
toxic i l y, and reactivity left s ide of K i ;v i r< • ">).
A waste placed 011 the haza rdous List may be demount. rat .>.1 I o l>e lonli.i,Mr-
dons by paaslnj; the nont nclus Ion tents on the r i ght i a r I,»«»r«- '>.
Fluldt^fid-bed combust Lon waste is not on the ha/, a rdous waste lists,
and, therefore, a determination of its hazardous or uouha.'.n rdous nature
raust be made by the mechanism .shown on the left of Figure *j. Vioii" the
hazardous characteristics con,-; ide red ~ ignitabi1ity, corros i vi t v , toxi-
city, and reactivity - toxicity, for which I'.PA It.is proponed .111 KP and a
hazardous criterion (10 x WI.PDWR) , causes the most concern far I'iJC r<-s L-
due. Because of the large voLunie of residue and the limited data on i t «-
potential hazard, BP A. has proposed a list: of "special wastes" under
Sec. 3004. These wastes a re:^
• Cement kiln dust
• Utility waste (fly ash, bottom ash, scrubber sludge)
• Phosphate mining, beneficiation, and processing waste
• Uranium mining and other mining waste
• Gas and oil drilling muds and oil production brines.
Should any of the above wastes be determined to bo hazardous accord i nj>
to the criteria in Sec. 3001 they will be regulated by special standards
with partial exemption from the cradle-to-grave regulations under
Sec. 3002-3005.
In addition to [gnitability, corrosivity, reactivity, and toxicity
currently proposed, four additional characteristics are to be considered
for hazardous waste Identification - mutagenicity, genetic activity,
bioaccumulat ton, and additional aspects of toxicity - as indi cated by an
Advanced Notice for Proposed Rulemaking (ANPR) P.PA issued in the same
Federal Register (Dec. 18, 1978) to solicit comments and Information.
Although these are being considered, they are not part of the currently
proposed Sec. 3001 regulations.
-------
Sections 3002 and 3003 provide standards for generators and trans-
porters of hazardous wasti'.s, These regulations were promulgated on Feb-
ruary 26, 1980. ^ Waste generators are required to determine if their
wastes are hazardous according to the criteria to be set forth in
Sec. 3001. Generators and transporters of hazardous waste must comply
with requirements provided by flee. 3002-3 (i.e., EPA/DOT regulations) on
packaging, labeling, record-keeping and manifest systems to assure that
the hazardous waste is delivered to the permitted treatment, storage, or
disposal facility designated by the shipper on the manifest.
Section 3004*- proposes standards for owners and operators of haz-
ardous waste treatment, storage, and disposal facilities. Standards for
landfill site selection and designs are provided in these regulations.
In essence, a landfill must be located at least 1.5 m (5 ft) above the
historical high water table and 150 m (500 ft) from any functioning pub-
lic and private or livestock water supply, and its leachate must be con-
tained with 1.5 m (5 ft) of natural, in-place soil with permeability
( 10~7 cm/s) or a membrane liner with leachate collection/removal sys-
tem. The owner/operator of a disposal facility must not only comply
with the requirements of the manifest system, record-keeping, and
reporting,but must also fulfill the technical and financial requirements
for postclosure care of at least 20 years.
Under Sec. 3005 a facility treating, storing, and disposing of haz-
ardous waste must apply for a permit confirming that the facility is
complying with Sec. 3004 standards. Under Sees. 3006, 3009, and 3011,
federal programs to assist and to authorize states in the development of
state hazardous waste programs are provided, if the state so desires,
provided the state's program is equivalent to (or more stringent than)
and consistent with the federal program.^
Sections 3007 and 3008 provide regulations for on-site inspection
and federal enforcement. Violation of standards set forth in
Sees. 3001-6 could result in a fine of $25,000/day or one year's Impris-
onment (double for second offenders).
25
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Under Sec. 3010 anyone go.no rat lag or transporting hazardous waste,
or ownin;; or operating a t reatmont, storage,or di sposal f ao i t i ty , is
required to file with EPA a notification of its hazardous waste activity
within 90 days of the promulgation of regulations of Sec. 3001 on iden-
tification and listing of hazardous waste.
N'onhazardous Waste Disposal
If a waste is hazardous, it is subject to the cradle-to grave regu-
lations of Subtitle C, as discussed tn the previous section. On the
other hand, the disposal of a nonhazardous waste falls under the juris-
diction of Sec. 4004 (Criteria for Sanitary Landfills) of Subtitle I)
(State and Regional Solid Waste Plans) as well as Sec. 1008 (Solid Waste
Management Information and OuideIines). These regulations have boon
proposed (Federal_ Register Feb. b, 1978 and March 2f>, 1979)2'1 > •-•' and
recently promulgated (Sept. 13, 1979)^ to provide "Criteria for Class-
ification of Solid Waste Disposal Facilities and Practices; Final,
Interim Final, and Proposed Regulations." This regulation contains
minimum criteria for determining what solid waste disposal facilities
and practices pose a reasonable probability of adverse effects on health
or the environment. Those disposal facilities that meet these criteria
are called "sanitary landfills." Those facilities that violate the cri-
teria are "open dumps." EPA is directed to make an Inventory of all
open dumps except those operating under compliance schedules not to
extend beyond five years from Clie date of inventory. The Inventory will
provide for the state to provide a plan for closing or upgrading all
existing open dumps according to Sec. 4003, as open dumping is prohib-
ited under Sec. 4005.
Subtitle D of the act fosters this cooperative effort by providing
for the development of state and regional solid waste management plans
that involve all three levels of government - federal, regional, and
state EPA. As the federal partner in this process, EPA seeks, through
regulations and financial assistance, to aid state initiatives In the
formulation and implementation of plans.
26
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The three most important criteria published on sanitary landfills
Q
for nonhazardous solid waste disposal0 with the greatest impact on FBC
residue disposal are:
• Surface Water. The leachate and runoff from solid waste
disposal must not contaminate surface water. If it is a
"point source" discharge, it must comply with any National
Pollution Discharge Elimination System (NPDES)22 require-
ments developed under the CWA; if the runoff is considered
a nonpoint discharge, then the facility must comply with
any applicable water quality management plan prepared by a
state pursuant to Sec. 208 of CWA.
• Groundwater. Solid waste disposal must not contaminate
groundwater beyond its boundary. Should the groundwater
be a drinking water source, the groundwater at the dis-
posal facility boundary must not exceed the NIPDWR (Appen-
dix R) or cause an increase in the concentration of that
substance in the groundwater where the existing concentra-
tion of that substance exceeds NIPDWR. The NIPDWR mate-
rials covered in this groundwater requirement Include not
only the species indicated previously tn connection with
the EP, but also fluoride, nitrate, certaLn radioactive
contaminants (radium-226, radium-228, and gross alpha par-
ticle activity), and microbiological contaminants.
The September 13, 1979 Federal Register also includes a
proposed amendment to the promulgated Sec. 4004 criteria
for disposal facilities. This proposed amendment would
expand the list of contaminants considered in determining
groundwater contamination to include those species con-
tained in the National Secondary Drinking Water Regula-
tions (NSDWR) (Appendix These species Include pH,
SO4, and TDS, as well as chloride, color, copper, foaming
agents, iron, manganese, odor, and zinc. This proposed
27
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expansion in the list of cont.ini nants could have a si;;ni-
f leant impact on f'BC residues under . 4004, should it
become part of the leachate criteria in the future.
• Application to Land Used for Product ion of Food-Chain
Crops. Standards based on health and env'i ronnental ef foct
have been specified for cadmium and po lychl.o r i na ted
biphenyls (PCB) in the application of solid residue to
agricultural land. These criteria for cadmium could
affect FUC residue should it be utilized in agriculture.
INTKG RATION WITH OTHKR 1,1-T, [SLAT ION
Environmental Laws in addition to RCRA chat are of interest to
solid waste disposal include the following:
• Clean Water Act, 197/
- Federal Water Pollution Control Act, 1972
- Safe Drinking Uater Act, 19 74
• Clean Air Act Amendments, 1977
- Clean Act Act, 1970
• Toxic Substances Control Act (TSCA), 1977
• Occupational Safety and Health Act (0S11A), 1970
• Marine Protection, Research and Sanctuaries Act, 1972.
The integration of RCRA with this and other legislation represents an
important challenge to EPA to avoid duplicate effort and overlapping
authority. An example of such overlap has been seen in the previous
section between Sec. 4004 regulations of RCRA and tlie NPDKS program
under the Clean Water Act, when a solid waste disposal facility involves
a point source discharge to the surface water.
28
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The EPA lias already proposed consolidated permit program regula-
tion;; and application forms (Federal Register, June 14, 1979) for five
r\ /
p roj; rams innti-r four federal envt romnental Laws:'-'4
• The Hazardous Waste Management (HWM) program under the
Resource Conservation and Recovery Act
• The Underground Injection Control (ULC) program under
the Safe Drinking Water Act
• The National Pollutant Discharge Elimination System
(NPDES) program under the Clean Water Act
• The Prevention of Significant Deterioration (PSD) program
of the Clean Air Act
• State Section 404 (Dredge or Fill) programs under the
Clean Water Act.
If a state wishes, each of the permit programs included in the
consolidated regulations may be administered by a state instead of the
federal government. To obtain program authority from the U.S. EPA,
states must ensure that their programs comply with the federal
requirements.
29
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6. [< XPKRI MI'MTAL CR1TKIUA AND RKSIJLfS
HAZARDOUS WASTK [ DKMTI F I. CAT J ON CIUTKIUA
As discussed previously, should KBC waste prove to bi.> hazardous
according to RCRA Sec. 3001 guidelines, it would he regulated by the
provision "Hazardous Waste Management" under Subtitle C, most likely is
"utility" waste under the "Special Waste" category. On tin? other hand,
should FBC waste be identified as nonhazardous, it would fail under tin*
jurisdiction of Subtitle D, and its disposal would then be regulated as
a sanitary landfill waste.
As FBC waste is not on the list of hazardous wastes by processes
and sources under Sec. 3001, we need to determine if it possesses any of
the four hazardous characteristics - Igni t abi 11 t.y, corrosivity, reactiv-
ity, and toxicity - as Illustrated in the previous section in Figure "j
and further defined In Table 2.
Ignltabillty
Some residual carbon resulting from incomplete combustion of the
coal will remain In FBC waste. This residue, however, is considered
unlikely to cause fires through friction, absorption, moisture, spontan-
eous chemical changes,or retained heat.11 >25,26
Corrosivity
Although corrosivity Is of some concern because of the high piI (In
the range of 9 to 13) of leachate of FBC bed material, the pll criteria
(<3 or >12) applies only to aqueous wastes and not to the leachate from
a dry, solid waste. Thus, FBC residue is not considered corrosive
30
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Table 2
:>i-3K LMITION OF THE CHARACTKRiSTiCS OF A HAZARDOUS WASTK*
Character! sties
Igni table Uaste
Corrosive Uaste
Reactive Waste
TokIc Waste
Def ini t ton
• Is a liquid and lias a flash point lower than f>0°C
• Is not a liquid and is liable to cause fires
through friction, absorption of moisture, spon-
taneous chemical changes, or retained heat From
manufacturing or processing, or when ignited burns
.so vigorously and persistently as to create a haz-
ard during Its management
• Is in ignitable compressed gas
• Is an oxidizer
• Is aqueous and has a pH loss than or equal to 3 or
greater than or equal to 12
• Corrodes SAE 1020 steel at a rate greater than
0.2 50 inches per year at a test temperature of
no°F
• Is normally unstable and readily undergoes violent
chemical change without detonating; reacts vio-
lently with water, forms potentially explosive
mixtures with water, or generates toxic gases,
vapors, or fumes when nixed with water; or is a
cyanide- or sulfide-bearing waste which can gener-
ate toxic gases, vapors, or fumes when exposed to
mild acidic or basic conditions
• Is capable of detonation or explosive reaction but
requires a strong initiating source or must be
heated under confinement before initiation can
take place, or reacts explosively with water
• Is readily capable of detonation or of explosive
decomposition or reaction at normal temperatures
and pressures
Is a forbidden explosive,
a Class B explosive
a Class A explosive, or
• Any material whose extract, after applying the
Extraction Procedure, is equal to or greater than
10 x the NIPDWS
*Source: Reference 2.
31
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according to Sec. TOOL- It Ls also worth noting that available data
suggest that the pH of leachate can be reduced t.o Less than 12 by codis-
posal of FBC bed overflow and carry-over materials.
_Reactivi ty
The CaO content of the FBC waste is mil i kt;ly to be considered
"reactive." Although CaO releases heat when initially exposed to water,
this reaction should not be sufficiently violent to classify tin- r.-sidue
as " reac t ive. " 2 5,26
Toxici ty
Of the four hazardous characteristics currently proposed, tlx- tox-
icity criterion could have the greatest impact on FI5C wastes. Experi-
mental efforts, therefore, have been directed toward dete rmi ni n;',, hv the
KP test, whether FBC residue is a toxic waste acc.ordi.ng to the RCRA
definition of toxicity.
HAZARDOUS WASTE IDENTIFICATION TESTS
Extraction Procedure Test Development
Table 3 summarizes the history of regulation development under RCRA
Sec. 3001 and the efforts Westinghouse has undertaken accordingly.
Table k lists the key differences among the leaching tests contained in
the previous draft versions, TEP,^ and the (Fed. Ref;. Dec. 18, 1978)
proposed regulations, EP.
The results of Westinghouse efforts In testing the TEP procedures
with residues from FliC processes and our recommendations were summarised
in an informal document entitled "Assessment of RCRA/TEP test results on
FBC residue, Part I" and communicated to EPA In December of 1978 (Appen-
dix A). Partial results and conclusions from our RCRA/EP tests on some
FBC residues were previously summarized and communicated to F.PA and sub-
sequently published in the Federal Register on Oct. 2, 1979. This sec-
tion represents our continued effort with the proposed KP procedures.
32
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Table 3
RCRA 3001 REGULATION1 DEVELOPMENT
Key Issues
Toxic Extraction Procedure, TEP,
drafted for hazardous waste
identification
Draft Proposed
Regulations Regulations
March 19 78
Dec. 18, 1978 •
Extraction Procedure, EP,
proposed—significantly dif-
ferent from the previous TEP.
A structural integrity test,
SIT specified for monolithic
block.
"Special Waste" Category cre-
ated (including utility waste):
subjected to partial exemption
of hazardous waste regulations.
Advance notice for Proposed
Rulemaking on radioactivity
and bioassay.
Vestinghouse
"TEP" initiated on selected
samples
• to assist RCRA Sec. 3001
development
• to provide initial indication
of "hazardous" or "non-
hazardous" nature of
res idues.
"EP" initiated on selected FBC,
reference materials, and raw
sorbents.
Act ions
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Table 4
ni'.VF.I.OPMKNT 100 g
Sample Preparation
Grinding to 3/8 in
Grinding to 3/3 in, or "SIT"
hammer test on monolithic block
Leaching Medium
Deionized water with NaOH
or acetic acid added
Deionized water with 0.5N
acetic acid added
Titrating Agent
IN NaOH or 1:1 acetic
acid
0.5N acetic acid
Maximum Titration
No limit
Maximun= 4n1/g solid
Final pH
4.9 - 5.2
4.9 - 5.2 or controlled by
maximum acid allowed
Temperature
Room temperature
! 20 - 403C
)
Extraction Time
2 x 24 hr = 43 hr total
24 hr single extraction
j
Solid/Liquid Ratio
1:10 for each extraction,
plus original liquor
l:2n plus original liquor
!
Agi tat or
Not specified
¦
Not spec i t iod , hit nvr'ie.id
stirring suggested
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Samp 1es
We investigated ,1 total, of 26 samples for potential hazard due to
toxicity by using RCRA/TEP and/or RCRA/EP tests. These were
• FBC residue. Seventeen FBC residues were selected to
include process variations: limestone/dolomite sorbent,
AFBC/PFBC boiler/PFBC adiabatic combustor, bed/carry-over
from < 1L t I < t r i* u t particulate collection stages, with/ with-
out carbon burnup cell (CBC), and with/without sorbent
regenerat Lon. These samples are summarized in Table 5.
The composition of the solids, as well as their leaching
•and thermal activities, have been investigated previously;
Appendix C presents data summaries of the sample cate-
gories tested here for RCRA. Detailed results of the FBC
residue study (on these and other samples) carried out by
Westinghouse since 1974 and the specific operating condi-
tions under which the residues were produced can be found
in other EPA reports.11>12,27
• FGD residue. Three FGD residues (untreated and stabi-
lized) were tested to provide a comparison of FBC results
with those from conventional sulfur-removal wastes. The
FGD sludge typically consists of calcium sulfite (CaSC^),
calcium sulfate (CaSO^), calcium carbonate (CaC03), and
coal ash. The chemical and physical properties of the
treated and untreated FGD residues are discussed in our
previous EPA report. 12 Appendix C presents a data summary
table.
• Conventional coal ash. Three bottom and fly ash samples
from two Western Pennsylvania conventional coal-burning
power plants were tested to provide comparison. The
ash samples typically contain quartz (SiC^) , hematite
(oi-FeoO 3) , mullite (3AI2O3 • 2SKJ2) , and spinel. Their
35
-------
T;ihie r)
SUMMARY OF FBC SAMPLKS T l-i SI" I ¦; I') US INC KCKA/ I'KI' AN'!) RC?. \/-.V
Samp 1
i2H
Bat telle Rod-'
Bat telle Carry-over,
cyclone
MERC Carry-over,
bagf i Lter
29
PV.ii Carry-over,
CBC residue
10
3\
Argonne C2/03 Red
Eea therhead Carry-over, -
prinary cyclone
Leatherhead Carry-over,
' .secondary cyclone
Exxon 73 Bed
Exxon 7 3 Carry-over,
9 n d c v c 1 o ne
Exxon 7 3 Carry-over,
3rd cyclone
Exxon 67 Carry-over,
3rd cyclone
Exxon 105 Combustor
Bed
Exxon 105 Regenerator
Bed
Exxon 105 Carry-over,
2nd cyclone
Exxon 105 Carry-over,
3rd cyclone
Lxxon 105 Regenerator
Carry-over
Combustion Power P-403^
Carry-over, baghouse
So rbent.
1' roecss Va rial ion
Li mestone
AFBC, once through
Li mes tone
AKIK.', once through
1,i ine s tone
AKBC, once throu);li
I, i me s t one
AFHC, once t li rou;'J i, with (!!4C
Do 1omi t e
I'FISC, once 1 h roiiy,h
Dolomi te
PFBC, once t h rou>',h
Do 1omite
PFBC, oner t 1 i r i n l j11
Do 1omit e
PFBC, once throni'.h
Dolomi t e
PFBC, once through
Dolomi te
PFBC, once r hroii);li
Do lomi te
PFBC, once thron)',h
Limestone
PFBC, with sorbent rejMMierat i on
Limestone
PFBC, with sorbent. regeneration
Limestone
PFBC, witli sorbent regeneration
Li me s tone
PFBC, with sorbent re;;c ne ra t i on
L i me stone
PFBC, with sorbent regeneration
Dolomi te
PFBC adiabatic, once through
*AFBC Units: Battelle (24 in); MERC (18 in); PER (0.46 x 1.83 n)
PFBC Units: Argonne (6 in); Exxon mini plant (32 cm combustor with
21.6 cm regenerator); Leatherhead (3 x 2 ft); Combustion
Power CPU - 400 PDU (adiabatic).
"36
-------
choni cal, physical and In aching properties have been sum-
mari/.cil c> I sowlio r> •; 35 data ;;nminartes are presented la
Appendix 0.
• Raw Sorbent. A J imestone and a dolomite sorbent were
tested Co provide perspective on sorbent prior to utiliza-
tion in FHn pr')ces!j<;s.
• Na_tura_l gypsum. A natural jypsum was tested to provide
perspective nil the extraction procedure on a natural min-
eral, since. CaSO/j is the major component of the FRC
res idue.
Procedures and Equipment
The BP procedures (Appendix D) as specified in the Federal Register
December IB we re followed, allowing for the following interpretat Lous ur
ad ju stine nt-s :
• "Representative Sample". We used 25 g instead of 100 g
because of the limited quantities of FBC solids available.
Based on our experience with FBC residue and because of
the granular nature of. the solids, however, we believe
that the samples (25 g) were representative.
• Neither the structural integrity test (SIT) nor the han-
dling of liquor was required for FBC residue because of
the nature of the solids (dry granular, <3/8 in).
• "Suitable extractor". We used an Eberbach automatic
shaker al: Its highest speed (140 excursions per ml n) and
found that it provided good solid/water mixing and pre-
vented stratification (see Appendix A). The high-speed
shaker was selected also because of the following:
The suggested extractor by Associated Design amd Manu-
facturing Co., Alexandria, VA was not commercially
available^ at the time we initiated the TCP tests.
37
-------
Oak Ridge National Labora tortus (ORNL), who were test-
ing the EP procedures under contract to the LPA Office
of Solid Waste, designed anil built their own exl ruction
apparatus. 3 7
After trying various agitation modi's, including mag-
netic stirring and agitation by automatic shaker at 70,
88, 108, and I AO excurs ions/mi n, wo chose to use the
automatic shaker at 140 exeursions/min (see Appendix \
for preliminary TF.P studies).
• A Chemtrix Type 4r>A pi! controller was used for automatic
titration of some samples. Prior to obtaining the auto-
matic titrator, we foL Lowed the manual pll adjustment pro-
cedures. Both performed satisfactorily.
Results and Discussion
Table 6 summarizes the trace elements found in the F.P leaehates and
compares them to the criteria for ha/.ardous waste, 10 x NTPDWR. in
addition to the metal elements for which LP criteria are currently pro-
posed, NO3 and F were determined for some samples because criteria for
these species were Included in the earlier draft (March 1978) of TSP.
All EP leaehates had Ag, As, Ba, Cd, Cr, Hg, Pb, and Se at concent ra-
tions below 10 x NIPDWR except for the leaehates of Exxon 10S (a PFliC
run with sorbent regeneration) carry-over from the 2nd cyclone which had
a larger amount of As. The higher than 10 x DWS value of arsenic would
cause this particular solid to be designated as "ha/.ardous waste" should
it need to be disposed of alone. Since the bed material and carry-over
from other cyclones are not toxic, however, with arsenic values several
orders of magnitude lower, and solids from different sources in the same
process would most likely be disposed of together, we believe that the
EP leachate of the mixture would be nontoxic. Nevertheless, It is
important to note that the EP leachate of the second cyclone carry-over
from a regenerative PFBC run alone had much higher levels of arsenic
than did the other EP leaehates and warrants special attention.
Although lower than the criterion, chromium was at much higher levels in
38
-------
Table 6
U*q. l.?liB59
L EACH AT K CIIARACTKKI ST [CS (TRACK KLRMENTS) FROM RCRA/EP TEST
Trace Elements, mg/f
Sample
r
Battelle Bed
Battelle Carry-over, cyclone
M[RC Carry-over. Iiai| filter
P[R Carry-over, CBC residue
Arrjonne C^/C^ Bed
Lealherhead Carry-over.
Primary cyclone
Leatherhead Carry-over.
2nd cyclone
Exxon No. 73 Bed
Exxon No. 73Carry over,
2nd cyclone
Exxon No. 73Carry-over,
3rd cyclone
Exxon No. 67 Carry over,
3rd cyclone
Exxon No. 105 Combuslor Bed
Ag
< 0. 02
¦: o. 02
¦ 0.02
¦ 0.02
As
9a Cd
Cr
N03
F (as Ni
0.001 <1 <0.01 0.09
O.OOl 1 <0.005 0.06
0.004 <1 <0.00 5 0.4
<0.001 <1 <0.01 0.04
Hg Pb Se
<0.0005 < 0.04 0.001 <1 <5
0.0007 <0.04 <0.001 <1 1.6
< 1 15
0.02 0.023 < 1
0.01 0.02
0.0006 < 0.04 0.01
0.0007 <0.03 <0.001 - -
<0.0005 <0.04 0.003 1.7 <5
"0.34 0.002 <1 <0.01 <0.05
0.0005 < 0.04 0.007 <1 <1
0.04 0.012 <1 <0.01 <0.05 0.0021 <0.04 0.008 <1 <1
0.04 0.002 <1 <0.01 <0.05 < 0.0005 < 0.04 0.003 <1 <1
0.04 0.002 <1 <0,0 1 0.06 0.001 <0.04 0.020 <1 <1
1 Exxon No. 105 Reqenerator Bed
(Exxon No. 105 Carry-over.
2nd cyclone
Exxon No. 105Carry-over,
3rd Cyclone
Exxon No. 105 Reqenerator
Carry-over
Combustion Power P-403
Carry-over, baghouse
<"0.04 <0.001 <1 <0.01 0.35
<0.02 0.007 < 1 0.045 <0.02
<0.02 <0.001 <1 <0,01 <0.05
<0.02 <0.001 <1 <0.01 0.15
<0.02 <1 <0,01 <0,05
<0.02 0.004 <1 <0.01 <0.05
0.0022 <0.04 0.017 <1 <1
0.0008 < 0.04 0.005 <1 <1
0.0006 <0.05 <0.001
0.0015 <0.01 0.004
0.0019 < 0.05 0.008
0.0012 < 0.05 0.007
0.02 <0.001 <1 <0.01 <0.05
0.0014 <0.05 <0.001
<0.02 <0.001 <1 <0.005 <0.02
UntreatedFGD Residue
Stabilized FGD Residue
Fly Ash No. 1
Fly Ash No. 2
Bottom Ash
Reference, dolomite sorbent
Reference, natural gypsum
Criterion. lOx NIPDWR
<0.04 0.069 <1 <0.01 <0.05
0.0009 <0.04 <0.001 -
0.0013 <0.04 0.017 4.2 «1
<0.04 0.058 <1 <0.01 <0.05 0.001 <0.04 0.08 1.7 ^1
<0.02 0.065 <1 <0.005 <0.02 0.0006 <0.04 0.02 <1 <1
0.03
<0.02 0.005 <1 <0.01 to
<0.05
0.0013 < 0.03 0.009
<0.02 <0.001 <1 <0.01 <0.03 0.0011 <0.03 <0.001
<0.02 <0.001 <1 <0.005 <0.02 0.0009 <0.04 <0.001 <1 <1
< 0.02 0.001 <1 <0.005 <0.02
0.5
0.0011 <0.04 <0. OOl <1 1.4
0.5
10.0 0.1 0.5
0.02
0. 5
0. 1
- = not analyzed
= exceeds 10 X NIPDWR
39
-------
three EP leachates than ia the others: AFBC anil PFBC fines from the 3rd
cyclone and bagf liter, and PFBC regenerator bed material had chromium
concentrations in their EP leachates (0.15 to 0.4 ppm) close to the
chromium criterion, 0.5 ppm. Samples from these sources, therefore,
should also be emphasized in future investigations.
As there is no reason to believe that the FBC residue would contain
chlorinated organic pesticides and herbicides, EP analyses for Lindane,
Methoxychlor, Toxaphene, 2.4-D and 2.4.5-TP Silvex,which were also pro-
posed In Sec. 3001,were not performed.
The characteristics of EP leachates la addition to their trace ele-
ment concentrations are summarized In Table 7. As expected, the major
species, such as calcium, SO4, and specific conductance (an approxima-
tion of TDS), were high in the EP leachates of FBC residues, although no
hazardous criteria were proposed for these substances. In most cases
the maximum allowable acid (4 ml of 0.5N acetic acid per gram of solid)
was reached so that the final pH was much higher than 5.
Table 8 summarizes Westinghouse results of Subtitle C tests based
on the currently proposed hazardous waste Identification methods. Work
by other investigators has been closely monitored and Is Incorporated in
the next section to assess the impact of RCRA on the disposal of FBC
residue.
NONHAZARDOUS WASTE DISPOSAL CRITERIA AND RESULTS
Because the EP test results indicated that FBC residue would most
likely be nonhazardous, Its disposal would be regulated under "sanitary
landfill" for nonhazardous waste under RCRA Subtitle D.
According to the regulations promulgated in the Federal Register on
September 13, 1979, leachate of a sanitary landfill should comply with
the NPDES requirements according to the Clean Water Act if it is a point
source discharge. Accordingly, the facility would have to employ the best
technology for reducing effluent emissions. Current regulations and
40
-------
Owy. 1"1:B58
Table 7
LEACHATE CHARACTERISTICS (MAJOR SPECIES) FROM RCRA/EP TEST
Sample
Total Volume
0.5 N Acetic
Acid Added/mi
Final
PH
Specific
Conductance
p mho/cm
Ca,
mg/i
. ^
o.
..... -... .. i
SO,"
4
mg ll
i
Battelle Bed
1003
11.99
12,000
3,144
0
2192. 5
Battel le Carry-over, cyclone
lOO3
12
11,730
3,156
7.2
902.5
MERC Carry-over, bag filter
lOO3
10.7
7,040
2,416
28.8
1,000
PER Carry-over, CBC residue
1003
11.73
11,400
2,752
2L6
840
Argonne
1003
9
7,800
1,440
926.4
1, 150
Leatherhead Carry-over,
primary cyclone
100a
9.52
7,520
1. 512
787. 2
1896.2
Leatherhead Carry-over,
secondary cyclone
44
5.3
4,910
960
446.4
2, 330
Exxon No. 73 Bed
100a
10.1
7,090
2,432
81.6
1,200
Exxon No. 73 Carry-over,
2nd cyclone
iooa
11.12
7,670
2,560
7.2
1, 060
Exxon No. 73 Carry-over,
3rd cyclone
iooa
9.2
7,100
1,520
667.2
1,395
Exxon No. 67 Carry-over,
3rd cyclone
16
5.02
5,900
472
931.2
2,800
Exxon No. 105Combustor Bed
1003
11.78
12,600
3,156
<10
850
Exxon No. 105 Regenerator Bed
lOCf3
11.85
12,600
3,128
<5
931
Exxon No. 105 Carry-over,b
2nd cyclone
iooa
7.72
to
7.78
7.140
to
7.620
2, 2%
to
2,420
69.6
to
74.4
960
to
1. 162
Exxon No. 105 Carry-over,
3rd cyclone
43
5.18
3,940
1.136
21.6
1,094
Exxon No. 105 Regenerator
Carry-over
iooa
11.73
12,100
3,016
24
682
Combustion Power P-403
Carry-over, Baghouse
100a
9.71
7,980
1,288
1051. 2
2,800
Untreated FGD residue
100a
6.32
6.440
2,140
8a 8
1,020
Stabilized FGD residue
88
5.35
5,550
1,744
64.8
737.5
Fly Ash No. 1
24
5.05
1,620
372
21.6
1,010
Fly Ash No. 2
35
4.98
2,630
580
64.8
590
Bottom Ash
8
5.13
790
152
14.4
151.5
Reference, dolomite sorbent
95
5.08
4,640
776
460.8
10.6
Reference, natural gypsum
11
5:02
2,190
600
9.6
830
3 Maximum allowable amount of 0. 5N acetic acid
^ Several samples tested
41
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Table 8
HAZARDOUS WASTE CRITERIA (RCRA SECTION 3001)
1
Characteristics
Status
Preliminary Indications
FBC Residue
Comment
1. Ignitability
Proposed Dec. 18, 1978 in
Fed. Reg. Scheduled to be
promulgated in April 1980.
Not Intended to be static;
to be reviewed periodically
after promulgation
No
2. Corrosivity
No
Current proposed regulations
apply only to liquid waste
pH >12 or *3, but not to
leachates of dry solid wastes.
3. Reactivity
No
"Sulfide-bearing waste which
can generate toxic gases"
...or, "reacts violently with
water".... Some uncertainty may
arise from the interpretation
of this qualitative statement,
especially with regard to
regenerative, PFBC residue.
4. Toxicity
No
Based on results of "EP"
leachates; pass 10 x primary
DWS
5. Radioactivity
Advanced Notice for Proposed
Ruleiftaking, Dec. 18, 1973
Comments/information invited
before formal proposal.
Preliminary results from
ORNL and ASTM indicated
FBC residue to be non-
toxic with respect to
mutagenicity, aquatic
and phytotoxicity^"^
6. Genetic Activity
7. Bioaccuraulation
8. Additional
Aspects of
Toxicity
-------
standards under CWA—in particular, effluent limitation guidelines and
new source performance standards for steam electric power plants—do not
specifically define "best technology" and effluent emission limits for
FBC. At the present time, therefore, effluent controls for utility (or
industrial) FBC units, including FBC residue disposal sites, would have
to be designed utilizing best engineering judgment. Among the current
guidelines for conventional steam electric power plants,^8 the effluent
guidelines for heavy metals (Fe and Cu) which are equal to or less
stringent than DWS are not expected to cause problem, since the FBC
leachates meet DWS. Similarly, the total suspended solids (TSS), oil
and grease from the FBC leachate, are expected to meet the standards.
However, ptl guidelines, 6.0 to 9.0 for power plant effluent,will, of
course, cause the most concern should the leachate from an FBC residue
disposal facility constitute a point-source discharge, since the pH of a
typical FBC leachate is frequently higher than 9.
According to the currently published RCRA Subtitle D regulations, a
sanitary landfill should not contaminate the groundwater at the facility
boundary to levels above the NIPDWR. In the same Federal Register
(Sept. 13, 1979), an amendment was proposed to add the secondary DWS
(NSDWR) to the standards. The primary and secondary DWS are given in
Appendix B. Table 9 summarizes typical FBC leachate characteristics,
and compares them with the primary and secondary DWS (NIPDWR and NSDWR).
The FBC leachate was generated by the 200-hr continuous shake test
(reported in detail in previous Westinghouse reports) and thus repre-
sents the maximum contamination release. Effects of soil attenuation
and further dilution before reaching the groundwater as well as dilution
by the groundwater are not incorporated in the 200-hr shake results.
Comparison of FBC leachate with primary DWS (NIPDWR) and secondary
DWS (NSDWR) indicate the following:
• Heavy metal elements meet DWS even without dilution and
are not expected to cause environmental problems. FBC
43
-------
Table 9
Dwg. 1712BS;
COMPARISON OF A TYPICAL FBC LEACHATE WITH THE DWS
(Leachate Generated by 200-hr Shake Method)
Substance
FBC
Leachate,
DWS, m
3/<
mgIt
NIPDWR
NSDWR
Al
Oto > 2
Ag
<0.05
0.05
" As
ff.55
B
0 to > 5
Ba
< 1
1.0
Be
<0.02
Bi
<0.04
Ca
>500
Cd
<0.01
0.01
Co
<0. 1
Cr
<0.05
0.05
Cu
< 1
1.0
Fe
<0.3
0.3
Hg
<0.002
0.002
Mg
<30
Mn
<0.05
0.05
Mo
<5
Na
0 to > 100
Ni
<0.1
Pb
<0.05
0.05
Sb
<0.5
Se
<0.01
0.01
Si
Oto 30
Sn
<1.0
Sr
0 to > 10
Ti
<2
V
<1
Zn
<3
_
5.0
Zr
<1
S(h
< 10
SO4
vioQb-^ooo\\\
250
CI
<250
250
F
<2.4
£4
NO3OSN)
<10
10.0
TOC
<30
pH
#£12\\\\
6. 5-8. 5
TDS
^0Qpto40(Xl\\
500
Specific
Conductance
0.5 to 10.0
millimho/cm
Color
None
15color units
Odor
None
3 threshold odor number
Foaming
None
0.5
Aqents
Radioactivity
Not determined
5pCi tl
Ra 226 & 228
Biological
None
4coliform/
Activity
100 ml |
[\X1 - exceeds DWS
44
-------
leachate has Ag, As, Ba, Cd, Cr, Hg, Pb, and Se below the
primary DWS; and Cu, Fe, Mn, Cu, and Zn below the secon-
dary DWS.
• Nitrate and fluoride meet the NIPDWR without dilution and,
thus, will be no problem.
• Chloride meets the NSUWR and is not expected to cause
environmental concern.
• Although the NSDWR are not part of the current standards for
groundwater, we have selected 10 x DSDWR as the criterion for
comparing with the worst-case leachate,following the assumption
by EPA and attenuation/dilution faction of 10 in formulating
hazardous waste criteria. Sulfate and TDS exceed NSDWR but are
within 10 x NSDWR and would not be expected to contaminate the
groundwater, provided that the disposal landfill is properly
designed to incorporate the site-specific parameters.
• The pH of a typical FBC leachate without dilution and soil
attenuation is higher than NSDWR (6.5 to 8.5) and may pos-
sibly require further control, should NSDWR become incor-
porated in the standards. Note, however, that interaction
with soil, which frequently is acidic, may play a critical
role in reducing the leachate pH to below the NSDWR. Pre-
liminary data from the current Westinghouse laboratory
studies (under the same EPA contract) indicate that the
leachate pH can be effectively reduced after exposure to
clay materials—for example, montmorillonite and
kaolinite.
• Color, odor, and foaming agents which are in the NSDWR
are not expected to cause problems since the FBC leachate
is generally colorless, odorless and does not contain
foaming agents.
45
-------
• Radionuclides (Ra-226, Ra-228, and gross a-particle
radioactivity) were aot tested in this study, as we
expect them to be similar to the leachate of the conven-
tional power plant residue.
• Microbiological contaminant in FBC leachate was tested by
the Westinghouse Biological Group. The FBC leachate
causes little environmental concern due to biological
activity. No coliform bacteria were found in any of the
leachates tested--from bed material, secondary, and third
cyclone catches. Both the high FBC process temperature
and the highly alkaline leachate are factors attributing
to zero microbiological activity.
• The low Cd content in FBC solid and the high pH of leach-
ate assure that the Cd standard for agricultural applica-
tion (annual application rate less than 0.5 to 2.0 kg per
hectare on land use with a higher rate allowed for higher
pH) can be met without difficulty.
The NSDWR, which defines criteria for copper, iron, manganese,
zinc, chlorine, SO4, TDS, pH, color, odor, and foaming agents, is not
currently part of RCRA. We have assessed these criteria, however,
because they have been proposed for inclusion in addition to those In
the N1PDWR for groundwater.®
46
-------
7. ASSESSMENT OF RCRA IMPACT ON FBC RESIDUE DISPOSAL
RCRA test results indicate that the FBC residue would be nonhazar-
dous according to the currently proposed definition under RCRA Sec. 3001
as would the conventional utility wastes (FGD residue and coal ash),
based on test results from limited samples. Since FBC residue appears
to be nonhazardous according to the current RCRA Sec. 3001 definition,
it would not be subject to the costly cradle-to-grave regulation under
RCRA Subtitle C—Hazardous Waste Management. Instead, it would be regu-
lated as a "sanitary landfill" residue under Subtitle D—state and
regional solid waste plans—which is almost as stringent in regulating
site selection and disposal facility design, operation, and monitoring
but is much more relaxed in the requirements for generation, transporta-
tion,and manifest system of the solid waste.
IMPACT OF NONHAZARDOUS WASTE DISPOSAL REGULATIONS ON FBC RESIDUE
DISPOSAL (Subtitle D)
According to the current regulations promulgated on September 13,
1979, eight criteria, including site selection and leachate monitoring,
apply to the nonhazardous solid waste sanitary landfills where FBC waste
would most likely be disposed of. The most important issues are the
protection of ground- and surface water. Compliance with RCRA and NPDES
under CWA is required. Efforts by EPA are under way to consolidate the
solid waste permit system. Since effluent guidelines for FBC units and
FBC residue disposal facilities are unavailable, the best engineering
judgment for designing, operating, and managing the disposal facility
is required to avoid potential adverse environmental effects. FBC resi-
due disposal is expected to meet the current standards for sanitary
landfill—groundwater at the disposal facility boundary meeting the pri-
mary drinking water standards (NIPDWR, Appendix B). Should the
47
-------
secondary DWS (NSDWR) be included as is proposed, however, FBC Leachate
pH would be a major concern: the pH of a typical FBC Leachate ranges
from 9 to 12, while the pH NSDWR ranges from 6.5 to 8.5. The TDS and
S04 are of marginally passing values if a ten times attennation/diLution
factor is assumed. As soil attenuation can play a major role in reduc-
ing leachate pH, TDS, SO^, and calcium, site selection and disposal
facility design are critical factors in determining if leachate control
might be required. The potential environmental impact of FBC residue
depends, in general, not only on waste characteristics but also on site-
specific factors (such as hydrology, geology, climate, and soil charac-
teristics) and the design, operation, and management of the disposal
facility. Contamination due to trace metal elements and microbiological
activity is not expected. Radioactivity, if any, should be similar to
that of a conventional power plant residue.
IMPACT OF HAZARDOUS WASTE MANAGEMENT REGULATIONS ON FBC RESIDUE DISPOSAL
(Subtitle C)
With the exception of Sec. 3002 and 3003 (standards on generators
and transporter (Fed. Reg. Feb. 26, 1980)), regulations under Subtitle C
for "Hazardous Waste Management" had not been promulgated prior to the
completion of this study. The assessment presented here, therefore, is
based on the proposed regulations of December 1978. (Fed. Reg. Dec. 18,
1978).
• FBC residue nonhazardous. We have identified FBC residue
as nonhazardous according to the proposed Sec. 3001 regu-
lations prior to their promulgation. Although satisfying
the current standards, specific elements (As, Cr) have
been identified for specific FBC solids (carry-over fines
<15 pm and PFBC residue with sorbent regeneration) as
being in much higher concentration than in the average FBC
leachate and therefore warranting special attention in
future investigations.
48
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• Special Waste Category. Because of their large volume> as
well as the limited information available on them, six
wastes, including utility waste, are proposed as "special
wastes" and will be subject to partial exemption from the
cradle-to-grave regulation of Subtitle C, should they be
determined to be hazardous. Although results indicate
that the FBC residue would be nonhazardous and, there-
fore, need not be subject to the regulations on "special
waste category" under RCRA Sec. 3004, the proposed "spe-
cial waste," utility wastes included, do not mention FBC
residue. We recommend, therefore, that the FBC waste
(both from utility and industrial units) be added to the
list of utility wastes that currently includes FGD, bottom
ash, and fly ash, should any FBC residues produced under
specific conditions be determined to be hazardous.
• The Structural Integrity Test (SIT). Should FBC residue
be disposed of as a monolithic mass (after being processed
to reduce its environmental impact), the structural inte-
grity test (SIT)—the sample preparation procedure pre-
ceding the EP test for leachability—will be relevant to
its disposal. Since the unprocessed FBC solids were found
to be nonhazardous, however, we do not expect the pro-
cessed forms to prove hazardous unless other solids which
may prove hazardous are processed with them.
• Bioassays and Radioactivity. Although bioassays and radi-
oactivity have been considered in listing the hazardous
wastes by processes and sources, they are not included in
the currently proposed identification methods for haz-
ardous characteristics (ignitability, corrosivity, reac-
tivity, and toxicity) and, thus, were not tested in our
investigation on FBC residues. EPA, however, is consider-
ing an expansion of the hazardous characteristics to
include radioactivity, genetic activity, bioaccuraulation,
49
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and additional aspects of toxicity (Advance Notice for
Proposed Rulemaking, Fed. Reg. Dec. 18, 19 7 8)•^ Uncer-
tainties still exist in many dimensions such as the com-
patibility of biological testing with the acetate-based EP
leachate, reliability of the various specified procedures
(mutagenicity, bioaccumulation, aquatic toxicity, and
phytotoxicity), and interpretation of the results. EPA is
currently inviting information and comments. Oak Ridge
National Laboratory has conducted bioassays on fossil fuel
residues under a DOE and EPA contract and found the fol-
lowing results (Table 10).5>6 residue showed negative
results in mutagenicity, aquatic toxicity, phytotoxicity, and
metal elements, which agreed with our conclusion that it would
be nonhazardous. ASTM D19.12 also carried out bioassay
tests; the results are less conclusive because of diffi-
culty encountered in preparing the sample in test proce-
dures and in interpreting the test results.^ Radioactivity
was not part of the proposed tests in the identification
mechanism and thus was not measured in this study, but we
expect it to be similar to that of a conventional power
plant residue.
• Best Approach for Identifying Hazardous Waste. Experts
differ in their opinions about the best approach to iden-
tifying hazardous waste: the "single-test" approach
(which differentiates solid wastes into hazardous or non-
hazardous) versus "multitest" screening (which may clas-
sify wastes into degree of hazardousness). In the former
approach, EPA-OSW has proposed an extraction procedure to
which we react favorably on the basis of our experience
with FBC solids, which are primarily inorganic in nature.
On the other hand, because solid wastes differ in their
chemical and physical characteristics, and because a waste
can be hazardous or nonhazardous depending not only on the
50
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Table 10
TOXICITY OF EP EXTRACTS FROM FOSSIL-FUEL PROCESS RESIDUES BY ORNLa
Bioassay
Metal
Aquatic
Solid Waste
Toxicity
Toxicity
Phytotoxicity
Mutagenicity
FBC Residue
_
Power Plant No. 1 - Fly Ash
-
+
-
- Bottom Ash
-
-
+
-
- Scrubber Sludge
-
-
+
-
- Treated Scrubber Sludge
-
-
+
-
Power Plant No. 2 - Fly Ash
-
-
-
-
Gasification Bottom Ash No. 1
-
-
-
-
Gasification Bottom Ash No. 2
-
+
-
-
Gasification Bottom Ash No. 3
-
-
+
-
aSource: Reference 6
+ Toxicity
- Nontoxicity
-------
intrinsic properties of the waste but also on where and
how it is disposed of, we feel that an approach based on
"degree of hazardousness" on a site-specific, multitest
screening basis deserves serious consideration.
• Hazardous Waste Disposal Facility Design. Should any FBC
residue be found to be hazardous, it must be disposed of
in a permitted hazardous disposal facility. According to
the proposed Sec. 3004 regulations (Federal Register,
Dec. 18, 1978), the landfill shall be designed at least
1.5 meters above the historical high water table and at
least 150 m from any public or private water supply. The
design of the landfill shall be such that leachate can be
collected, removed, and treated. This is accomplished by
having an underlying liner, either of >1.5 m of natural
in-place soil with a permeability equal to or less than
1 x 10-^ cm/s or by using a membrane liner system for
leachate collection. In addition to the requirements for
landfill site selection and design, a hazardous disposal
facility must comply with stringent standards including
security, emergency plan, manifest system, and closure and
postclosure care. The cost impact can be significant.
Should any FBC residue be designated as hazardous, further proces-
sing to render it nonhazardous would be highly recommended. The deci-
sion, of course, would depend on the economic trade-off between the costs
for hazardous disposal and the cost for processing the residue to render
it nonhazardous for disposal based on the waste-specific and site-
specific factors.
IMPACT OF RCRA ON FOSSIL-FUEL ENERGY FACILITIES
Impact of RCRA on Utility Solid Waste
The regulations implementing RCRA pose new levels of control for
the traditional solid waste disposal process and establish a new set of
52
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cradle-to-grave standards for hazardous waste. Recent EPRI-^ studies
indicated that some utility wastes could be classified hazardous. EPA
has recognized the seriousness of these possibilities and has designated
utility waste among the high volume "special wastes" should they be
determined to be hazardous. Solid residues from emerging coal technolo-
gies, such as FBC, are expected to belong to this category should any be
identified as hazardous. The same EPRI study concluded that among the
hazardous characteristics the major concern for utility waste is toxic-
ity, followed by corrosivity and radioactivity. The regulation frame-
work used in the EPRI study was the March draft of Sec. 3001 regula-
tions, which was substantially different from the currently proposed
version. It is fair to conclude, however, that there is an insufficient
data base for the utility waste, particularly in radioactivity and bio-
assays, and further investigation is required.
Impact of RCRA on Siting of Fossil-Fuel Energy Facilities
RCRA will affect not only the technology and costs of existing
fossil-fuel plants, but probably also future facility siting decisions.
The key aspects of the Act that probably will influence the siting of
new energy facilities are provisions for hazardous and solid waste dis-
posal (Subtitle C and D) and provisions for resource recovery
(Subtitle E).
RCRA Subtitle D discourages facilities from being sited in areas
with sandy soils, with high groundwater tables, in floodplains, in high
seismic risk areas, in critical habitats, in areas characterized by
heavy rains, or in areas with high alternative use values. Energy
developers will favor sites that are high, dry, and close to clay depos-
its (e.g., bentonite) for less expensive waste storage and disposal.
Urban areas will be avoided because most cities already face serious
problems in disposing of municipal waste. Low-ash coal will be more
attractive because of the smaller amount of waste produced.40,41 Cal-
zonetti indicates that because the largest deposits of low-ash coal
53
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occur in the West, RCRA may increase the attractiveness of western sites
over eastern ones.^ RCRA encourages resource recovery, and markets for
ash utilization and sulfur recovery will play a role in siting. Loca-
tions adjacent to rivers or other bodies of water will be preferred
because they provide inexpensive transportation for wastes and recovered
materials. Finally, in light of the awareness created by RCRA, public
support or opposition is becoming increasingly important in deciding the
siting of fossil-fuel energy facilities.
Impact of RCRA on FBC Economics
The economics of fluidized-bed combustion systems (cost of elec-
tricity, steam cost, etc.) are very sensitive to the total cost of sor-
bent (sorbent purchase, delivery, and solid waste disposal cost reported
on a fresh sorbent basis). While the waste solids from FBC processes
are not likely to be classified as hazardous, some increase in sorbent
disposal cost may occur. The major cost increase would result from the
need to find a suitable disposal site that fulfills the RCRA require-
ments but may have associated with it high transportation costs. Other
disposal site costs are expected to result in less significant increases
in FBC costs. Such increases would be site dependent. Figure 6 indi-
cates the impact of the total cost of sorbent on the cost of electricity
for electric utility AFBC and PFBC systems.^ a conventional plant with
lime slurry scrubbing is also shown. Greater sensitivity to total sor-
bent cost is seen for the FBC systems, and the required Ca/S ratio is an
important factor.
The sensitivity shown may lead FBC developers to consider more
seriously alternatives to reduce the Ca/S ratio if RCRA does result in
an increase in solid waste disposal cost (e.g., optimum operating condi-
tions or advanced sulfur removal systems), or methods to reduce cost
increases resulting from RCRA (e.g., solid waste processing or
utilization).
54
-------
70
60
€ 50
40
30
Otrve 6%9?8-A
1 7 i | , 1
Eastern Coal (4 wt% Sulfur, 10wt% Ash)
PFBC
AFBC
Conventional Plant with Lime .
Slurry Scrubbing (Ca/S = 1.1) /
Stacfc Rehea'. of 79°C /
0 10 20 3 0 40 50 60
Sorbent Costl$/Mg)
Figure 6 - Effect of Sorbent Cost on the Economics of AFBC
and PFBC Systems*
*Sorbent cost can be defined to include disposal costs.
55
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8. REFERENCES
1. Resource Conservation and Recovery Act, Public Law 92-580, 1976.
2. Environmental Protection Agency, Hazardous Waste: Proposed Guide-
lines and Regulations and Proposal on Identification and Listing,
Federal Register, December 18, 1978.
3. Environmental Protection Agency, Hazardous Waste Guidelines and
Regulations - Criteria, Identification, and Listing of Hazardous
Waste, Draft, March 1978.
4. Environmental Protection Agency, Hazardous Waste Guidelines and
Regulations, Supplemental Proposed Rule, Federal Register,
August 22f 1979.
5. Epler, J. L., et al., Toxicity of Leachates, report to DOE and EPA,
Oak Ridge National Laboratory, Oak Ridge, TN.
6. Francis, C. W., M. P. Maskarinec, J. L. Epler, and D. K. Brown, The
Utility of Extraction Procedures and Toxicity Testing with Solid
Wastes, submitted to Annual Symposium on Solid and Hazardous Waste,
Chicago, IL, March 17-20, 1980.
7. Hanson, D. M., Testing Program for Assessment of Hazardous Waste
Characteristics Under Section 3001 of the Resource Conservation and
Recovery Act, in ASTM D19.12 Presentation, presented at Bioassay
Systems, Ft. Lauderdale, FL, January 1980.
8. Environmental Protection Agency, Criteria for Classification of
Solid Waste Disposal Facilities and Practices; Final, Interim
Final, and Proposed Regulations, Federal Register, September 13,
1979.
56
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9. Clean Water Act, Public Law 95-217 1977; Federal Water Pollution
Control Act, Public Law 92-500, 1972.
10. Clean Air Act, Public Law 95-95, 1970-1977.
11. Sun, C. C., C. H. Peterson, R. A. Newby, W. G. Vaux, and
D. L. Keairns, Disposal of Solid Residue from Fluidized-Bed Com-
bustion: Engineering and Laboratory Studies, report to EPA, West-
inghouse Research and Development Center, Pittsburgh, PA, March
1978, EPA 600/7-78-049, NTIS PB 283-082/6ST.
12. Sun, C. C., C. H. Peterson, and D. L. Keairns, Experimental/
Engineering Support for EPA's FBC Program: Final Report, Volume 3,
Solid Residue Study, report to EPA, Westinghouse Research and
Development Center, Pittsburgh, PA, January 1980, EPA 600/7-
80-015C.
13. Sun, C. C., C. H. Peterson, and D. L. Keairns, Environmental Impact
of FBC Residue Disposal. Proceedings of the 5th International Con-
ference on Fluidized Bed Combustion, Washington, DC, Decem-
ber 12-14, 1977, McLean, VA: The Mitre Corporation; 1978.
14. Ahmed, M. M., D. L. Keairns, and R. A. Newby, Effect of Potential
New Source Performance Standards on the Performance and Cost of
Industrial Fluidized-Bed Combustor Steam Generators, report sub-
mitted to EPA, Westinghouse Research and Development Center, Pitts-
burgh, PA.
15. Newby, R. A., et al., An Assessment of Advanced Sulfur Removal Sys-
tems for Electric Utility AFBC, presented at the 6th International
Conference on Fluidized Bed Combustion, Atlanta, GA, April 9-11,
1980.
16. Sun, C. C., and D. L. Keairns, Comparison of the Environmental
Impact from the Disposal of FBC and FGD Residues, presented as
preprint of paper, Division of Environmental Chemistry, ACS Meet-
ing, Honolulu, HA, April 1-6, 1979.
57
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17. Corson, A., D. Friedman, and D. Viviani, Hazardous Waste Management
Division, EPA-OSW, private communications 1978-1980.
18. Hazardous Waste Management: Overview arid Definitions; Generator
Regulations; Transporter Regulations, Environmental Protection
Agency, Federal Register, February 26, 1980.
19. Environmental Protection Agency, State Hazardous Waste Programs,
Proposed Guidelines, Federal Register, February 1, 1978.
20. Environmental Protection Agency, Solid Waste Disposal Facilities,
Proposed Classification Criteria, Federal Register, February 6,
1978.
21. Environmental Protection Agency, Landfill Disposal of Solid Waste,
Proposed Guidelines, Federal Register, March 26, 1979.
22. Environmental Protection Agency, National Pollutant Discharge Eli-
mination System; Revision of Regulations, Federal Register, June 7,
1979.
23. Environmental Protection Agency, National Secondary Drinking Water
Regulations, Final Rule, Federal Register, July 19, 1979.
24. Environmental Protection Agency, Draft Consolidated Permit Applica-
tion Forms and Proposed National Pollutant Discharge Elimination
System Regulations, Federal Register, June 14, 1979; Proposed Con-
solidated Permit Regulations, Federal Register, June 14, 1979.
25. Henschel, D. Bruce, Assessment of Fluidized-Bed Combustion Resi-
dues, EPA, October 1979, to be published in the J. of Eng. Div.,
American Society of Civil Engineers.
26. Keairns, D, L. , C. C. Sun, C. H. Peterson, R. A. Newby, Fluid-Bed
Combustion and Gasification Solids Disposal. Proceedings of the
Workshop on Solid Waste Research and Development Needs for Emerging
Coal Technologies, ASCE, San Diego, CA, April 23-25, 1979.
58
-------
27. Keatrns, D. L., et al. , Fluidized Bed Combustion Process Evalua-
tion, Phase II-Pressurized Fluidized Bed Coal Combustion Develop-
ment, report to EPA, Westinghouse Research and Development Center,
September 1975, EPA-650/2-75-027c, NTIS PB 246-116.
28. Hall, A. M. , Testing, Identification, and Evaluation of Commercial
and "Advanced Experimental" Materials and Coatings under Design
Conditions Simulating Fuel Power Cycle Combinations, Task II,
Monthly Technical Progress Report No. 12 to ERDA, Battelle-Columbus
Laboratories, Columbus, OH, June 6, 1977, FE-2325-12.
29. Wilson, J. S., and R. Rice, EPA-sponsored FBC run, Morgantown
Energy Research Center, Morgantown, WV, March 31, 1977.
30. Multicell Fluidized Bed Boiler Design Construction and Test Pro-
gram, Interim Report No. 1, Pope, Evans and Robbins, Inc.,
August 1974, PER-570-74.
31. Jonke, A. A., et al. , Annual Report on a Development Program in
Pressurized Fluidized-Bed Combustion, Argonne National Labora-
tories, Argonne, IL, July 1976, ANL/ES-CEN-1016.
32. American Electric Power, PFBC Project at CURL Leatherhead Test
Facility - AEP Test 7, July 1978.
33. Studies of the Pressurized Fluidized-Bed Coal Combustion Process,
Office of Research and Development, report to EPA, Exxon Research
and Engineering Co. , Linden, NJ, September 1977, EPA-600/7-77-107,
NTIS PB 272-722.
34. Energy Conversion from Coal Utilizing CPU-400 Technology, Combus-
tion Power Company, Contract No. E(49-18)-1536, March 1976.
35. Advanced Coal Gasification System for Electric Power Generation,
Quarterly Progress Report to U.S. Department of Energy, Westing-
house Electric Corporation Advanced Coal Conversion Department,
Madison, PA, January 1980, Contract EF-77-C-01-1514.
59
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36. Varouxis, Associated Design and Manufacturing Co., Alexandria, VA,
private communication, October 1978.
37. Arora, H., Oak Ridge National Laboratory, Oak Ridge, TN, private
communication, October 1978.
38. Code of Federal Regulations, 40, Protection of the Environment
Environmental Protection Agency, Part 423 - Steam Electric Power
Generating Point Source Category, Washington, U.S. Government
Printing Office; 1978.
39. Hart, F. , and B. DeLaney, The Impact of RCRA (PL 94-580) on Utility
Solid Wastes, report to EPRI, Fred C. Hart Associates, Inc., New
York, NY, August 1978.
40. Calzonetti, F. J., Impacts of the Resource Conservation and Recov-
ery Act on the Siting of Coal Conversion Energy Facilities in the
United States, report to Oak Ridge National Laboratory, Department
of Geology and Geography, West Virginia University, Morgantown, WV,
February 1979, 0RNL/0EPA-12.
41. Carnes, S., The Siting and Institutional Impacts of RCRA. Proceed-
ings of the ASCE/PRC-EPRI Workshop, Solid Waste Research and Devel-
opment Needs for Emerging Coal Technologies, San Diego, CA,
April 23-25, 1979, Oak Ridge National Laboratory, Oak Ridge, TN.
42. Newby, R. A., N. H. Ulerich, E. P. O'Neill, D. F. Ciliberti, and
D. L. Keairns, Effect of SO2 Emission Requirements on Fluidized-Bed
Combustion Systems: Preliminary Technical/Economic Assessment,
report to EPA, Westinghouse Research and Development Center, Pitts-
burgh, PA, October 1978, EPA-600/7-78-163.
60
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APPENDIX A
ASSESSMENT OF RCRA/TEP TEST RESULTS ON FBC RESIDUE
PART I - EPA DRAFT PROCEDURE OF MARCH 1978
I. INTRODUCTION
The most Important environmental law affecting solid waste disposal
is the Resource Conservation and Recovery Act (RCRA) of 1976 (the Solid
Waste Disposal Act of 1965, as amended by P.L. 94-580, 1976).^
Under the initial implementation strategy,2 EPA is focusing on
three provisions: identification of hazardous waste characteristics;
listing of hazardous wastes; and preparation of guidelines for handling
and disposition of wastes. Subtitle C of RCRA covers hazardous waste
management and deals with identification and listing of hazardous waste.
Under the authority of Sec. 3001, EPA is currently developing criteria
for identification methods (tentatively) for hazardous waste, which may
be one or more of the following: ignitable, corrosive, infectious,
reactive, radioactive, or toxic.3
Under title 40, Chapter 1, Part 250 - "Hazardous Waste Guidelines
and Regulations," Subpart A and Sec. 250.13 - of the March draft, a TEP
procedure has been identified to serve as a standard leaching test. The
resultant leachate (TEP extract) will be compared with the criteria set
forth in Sec. 205.12 for hazardous waste.
Since the RCRA/TEP test is designed to provide a generalized stan-
dard test with which to evaluate the "hazardous" or "nonhazardous"
nature of all solid wastes, we feel that it is important to carry out
such tests (draft procedure) on "typical" FBC residues and to communi-
cate to the EPA Hazardous Waste Management Division any difficulties or
61
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problems encountered with this type of waste. The information may then
assist EPA personnel to make further modification and complete the final
version of RCRA/TEP.
2. EXPERIMENT
The sections on equipment and procedures are direct excerpts from
Sec. 250.13 of the March draft of "Hazardous Waste Guidelines and
M 1
Regulations. J
2.1 Equipment
1. An agitator which, while preventing stratification of sample
and extraction fluid, also insures that all sample surfaces are
continuously brought into contact with well mixed extraction
fluid.
2. Equipment suitable for maintaining the pH of the extraction
medium at a selected value.
2.2 Procedure
1. Weigh a representative sample of the waste to be tested. Sep-
arate sample into liquid and solid phases by either centrifuga-
tion followed by filtration of the liquid through a 0.4 to
0.5 micron filter media or by pressure filtration using a 0.4
to 0.5 micron filter having a surface area of at least 0.5 cm
sq per gram of sample. Save the liquid for further use.
2. Grind the solid material, if necessary, to pass through a
9.5 mm (3/8 in) standard sieve.
3. The solid material is taken and added to eight times its weight
of deionized water. The pH of the solution is then adjusted to
pH 5 with 1:1 acetic acid or IN sodium hydroxide. Samples are
to be agitated during pH adjustment. pH measurements are to be
determined electrometrically following standard calibration
procedures.
4. Samples are to be maintained at room temperature during extrac-
tion. Samples are to be agitated for a period of 24 ± 0.5
62
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hours with pH to be maintained during leaching within the range
of 4.9 to 5.2. The preferred method of maintaining pH is with
automatic titration. if the necessary equipment is not avail-
able, manual, procedures can be employed.
5. At the end of the 24 hour extraction period the solution is
filtered as in step 1. The filtrate is then adjusted with dei-
onized water so that its volume is 10 times the initial weight
of solid sample [v(cc)/w(gui) ]. The liquid is combined with the
original liquid phase and the solid reextracted with fresh
extractant as in steps 3 and 4.
6. At the end of the second extraction period the mixture is fil-
tered, the concentration adjusted as in step 5, and the liquid
phase combined with that from the previous separations. This
combined liquid, and any precipitate that later forms, is des-
ignated as the Toxicant Extraction Procedure eluate.
The TEP eluate generated from the above procedure is hereby refer-
red to also as the leachate unless specified otherwise.
2.3 Samples
Six FBC residue samples were selected for preliminary RCRA/TEP
tasks to include process variations: limestone/dolomite, AFBC/PFBC/
adiabatic, bed/cyclone/additional filter. A FGD sludge was also tested
for comparison. Raw sorbents (limestone and dolomite) and natural gyp-
sum were tested in parallel to provide references. These samples are
listed in Table 1.
2.4 Results
Since agitation mode is not specified in the draft RCRA/TEP proce-
dure, we chose to use magnetic stirring, which provides a vigorous stir-
ring action, for initial testing in order to provide the worst-case lea-
chate. All solids became very fine powder after leaching (through
physical abrasion and chemical neutralization and dissolution). The
63
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resultant leachates - the "TEP eluate" - were analyzed for major species
and trace elements, the latter being dictated by the draft hazardous
criteria under the authority of RCRA Sec. 3001.
Table 2 summarizes pH, specific conductance, calcium, magnesium,
SO^, and the total amount of 1:1 acetate acid (8.75N) used to reach
pH = 5.0 ± 0.1. Clearly, a large quantity of acid was required to neu-
tralize the highly alkaline FBC residue to achieve final pH = 5. This
was also true for the raw limestone and dolomite sorbents. Magnesium,
which previously has been found to be nonsoluble in the alkaline lea-
chate, is highly leachable in acetic acid leachate of pH = 5. (Note the
high magnesium concentrations in leachates of spent Argonne and PDU dol-
omite as well as of raw Tymochtee dolomite.)
Table 3 summarizes the trace element concentrations and compares
them with the toxic criteria, 10 x DWS. Several elements were found to
exceed the criteria when leachates were induced by the TEP method. It
must be pointed out that the vigorous magnetic stirring action probably
results in nearly complete extraction, which is not the objective of the
RCRA/TEP test.^
Since the degree of agitation is obviously important to the resul-
tant leachate quality, we then attempted to determine the leachate char-
acteristics as a function of agitation - 70, 88, 108, and 140
excursions/min on the automatic shaker and magnetic stir. Two samples
were selected for the investigation - Battelle spent limestone and
Argonne spent dolomite. Table 4 summarizes the major species in lea-
chates (TEP eluate) and the total amount of 1:1 acetic acid required. A
greater degree of agitation resulted in increased solid dissolution (Ca,
Mg. S0A, and TDS) and required a larger amount of acid to produce lea-
chate of final pH = 5. Again, the high magnesium concentrations are
noted. Trace elements are summarized in Table 5 for three agitation
speeds and compared with the hazardous criteria. It is interesting to
note that leachates induced by gentler agitation (shaker) did not
exceed the 10 x DWS criteria.
64
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Thus far, the leachates discussed have been the TEP eluate, I.e.,
combined leachates generated by two consecutive shakings. In TabLes 6
and 7 the leachate quality (as indicated by specific conductance) and
the total amount of acid required to reach pH of 5 for the first and
second 24-hr extracts and the final eluate (two extracts combined) are
summarized. High-speed agitation caused nearly total extraction from
the first 24-hr shake so that only very small amounts of acid were
needed in the second extract. The quality of the second 24-hr leachate
was much better than that of the first 24-hr eluate, where most of the
extractable species had been leached out. Another point to be noted
from Tables 6 and 7 is that the total amount of acid required and the
total dissolved solids in the leachates increased with increased agita-
tion because of the greater dissolution accelerated by physical
abrasion.
3. DISCUSSION
Preliminary results from RCRA/TEP tests indicated that some uncer-
tainties and potential problems exist in the draft (March 1978) TEP
procedure:
• Nonreproducibility may result from an unspecified agita-
tion mode, as it has been demonstrated that leachate char-
acteristics are agitation dependent.
• A large amount of acid is required to bring the extract of
alkaline solid such as limestone or dolomite-based sorbent
to a final pH of 5. This may be unnecessarily harsh on
alkaline wastes, since the leaching conditions are
unrealistic.
• The 1:1 acetic acid is a very concentrated solution of
8.75 N, therefore more likely to introduce titration error
than would a more dilute solution.
• The temperature of the mixture may be higher than room
temperature because of the exothermic hydration of spent
limes.
65
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These difficulties were communicated to the EPA Office of Hazardous
Waste Management (RCRA Sec. 3001), during a visit from Mr. Don Viviani^
and our subsequent conversations with him and Mr. David Friedman.^
Since our preliminary experiments with the Martch draft RCRA/TEP, a
new draft (September 1978) has been issued which incorporates many
changes including those recommended. The major changes are:
• The concentration of acetic acid used has been reduced
from 8.75 N to 0.5 N.
• It sets a limit to the maximum amount of acid added, not
exceeding 4 ml of 0.5 N acetic acid per gram of solid.
Thus, the final leachate of an alkaline waste may not
reach pH = 5.
• Only one 24-hr extraction is required.
• A wider range of temperature is allowed during leaching
(20° to 40°C), eliminating the need for cooling in
slightly exothermic systems.
• A structural integrity procedure is required for samples
larger than 95 inm (3/8-in) particle size or block. The
latter is of particular importance to the processed FBC
residue in compact form.
• An agitation method is suggested in the up-to-date draft,
but uncertainties still exist and further modification may
be expected.5-7
We are currently carrying out tests employing the most recent draft
procedure. Results should provide a data base with which to judge the
"hazardous" or "nonhazardous" nature of the FBC residue.
66
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Table 1
SUMMARY Of SAMPLES STUDIES USING RCRA/TEP TEST
Sample
Sorbent
Source
Process
BattelLe Bed
Limestone
Bed
AFBC
Battelle Carry-over
Limes tone
Cyclone
AFBC
MERC Carry-over
Limes tone
Bag-filter
AFBC
Argonne C2/C3 Bed
Dolomite
Bed
PFBC
Exxon 67 Carry-over
Dolomi te
3rd cyclone
PFBC
PDU-P403 Carry-over
Dolomi te
Baghouse
PFBC, adiabatic
Tymochtee Dolomite
Raw sorbent, reference
1359 Limestone
Raw sorbent, reference
Gypsum, Iowa No. 114
Calcium sulfate, reference
CSO Sludge
FGD sludge, reference
>98% fly-ash removal
67
-------
Table 2
LEACHATE CHARACTERISTICS (MAJOR SPECIES) FROM RCRA/TEP TEST*
Sample
Total Volume of 1:1
Acetic Acid Added
to Achieve & pH=5
PH
S. C. ,
millimho/cm
Ca,
mg/JI
Mg,
mg/SL
SO,,
mg h
Battelle Bed**
61.8
4.98
25. 5
16,400
542
1,273
Battelle Bed
61.0
5.03
17.7
8,712
372
768
Battelle Carry-over
48.2
5. 12
15.2
6,952
288
778
MERC Carry-over**
42.3
4.9
20.2
9,560
408
730
Argonne Bed
77.8
5.0
20.8
4,080
5,340
2,803
Exxon Carry-over
1.5
5.05
5.23
456
946
4,100
PDU Carry-over
74.7
5.03
21.2
5,120
4,128
2,240
Tymochtee Dolomite
hi.2
5.0
14.5
3,388
1,596
6.2
1359 Limestone
120.6
5.02
26.2
18,440
144
6.2
Iowa Gypsum
6. 25
5.0
3.16
632
28. 8
1,000
CSO FGD Sludge**
17.0
5.0
5.8
1,560
254
2, 193
i
*Agitation by magnetic stir.
**One 24-hr extraction only.
-------
Table 3
LEACHATE CHARACTERISTICS (TRACE ELEMENTS) FROM RCRA/TEP TEST*
Trace Elements, mg/Jl
Sample
Ag
As
Ba
Cd
Cr
F
Hg
NO3
(as N)
Pb
Se
Battelle Bed**
<0.03
0.13
2.5
0.036
0.92+
0.37
<0.001
<1
0.18
0.004
Battelle Bed
<0.03
0.075
M
•
00
0.018
0.60+
0.06
0.0012
<1
0.13
0.001
Bactelle Carry-over
<0.03
0.06
1.2
0.02
0.24
0.42
0-0012
<1
0.13
0.003
MERC Carry-over**
<0.03
0.96+
2.0
0.08
1.65+
0.33
0.0014
80
0.17
0.39+
Argonne Bed
<0.03
0.14
<1
0.014
0.2
1.0
<0.001
<1
0.16
0.005
Exxon Carry-over
<0.03
0.005
<1
0.052
0.1
0.45
0.0012
8
0.05
0.004
PDU Carry-over
<0.03
0.073
<1
0.13+
0.18
0.18
0.0021
36
0.17
0.008
Tymochtee Dolomite
<0.03
0.001
<1
0.012
0.1
1.8
<0.001
1
0. 1
0.001
1359 Limestone
<0.03
0.001
4
0.071
0. 1
0.28
<0.001
<1
0.23
0.001
Iowa Gypsum
<0.03
0.001
<1
0.003
0.1
0.22
0.0014
5
0.06
<0.001
CSO FGD Sludge**
<0.03
0.01
<1
0.005
0. 12
<0.001
8
0.03
0.015
10 x DWS
(NIFDWR, 1976)
0.5
0.5
10.0
0.1
0.5
14 to
24
0.02
100.0
0.5
0.1
*Agitation by magnetic stir
**One 24-hr extraction only
+Exceed 10 x DWS
-------
Table 4
LEACHATE CHARACTERISTICS (MAJOR SPECIES) AS A FUNCTION OF DEGREE OF AGITATION
Sample
Agitation,
excursions/min
Total Volume
of 1:1 Acetic
Acid Added
to Achieve
pH=5
PH
s. c.,
millltnho/cm
Ca,
mg/£
Mg,
mg j I
so4
mg/1
Battelle Bed
70
26.4
5.0
10.8
4160
48
710
88
37.1
5.1
13.0
5840
72
940
108
55.4
5.1
17.0
84 00
240
994
140
54.6
5.0
18.1
8040
336
1200
Hi-speed
magnetic stir
61.0
5.0
17.7
8712
372
768
Argonne Bed
70
9.8
5.0
5.64
1100
576
1445
88
20. 1
5.1
8.79
1560
1392
1993
108
40.7
5.0
13.9
2120
3000
2803
140
54.4
5.0
17.9
2820
3900
2718
Hi-speed
magnetic stir
77.8
5-0
20.8
4080
5340
2803
-------
Table 5
LEACHATE CHARACTERISTICS (TRACE ELEMENTS) AS A FUNCTION OF DEGREE OF AGITATION
Trace Elements,
rag/i
Sample
Agitation,
excursions/min
Ag
As
Ba
Cd
Cr
F
Hg
no3
(as N)
Pb
Se
Battelle Bed
70
<0.02
0.007
<1
<0.01
0.12
0.5
0.001
<10
<0.04
0.003
140
<0.02
0.042
<1
<0.01
0.28
0.3
<0.001
<10
<0.04
0.002
Hi-speed
magnetic stir
<0.03
0.075
1.8
0.02
0.60+
0.13
0.0012
<10
0.13
0.001
Argonne Bed
70
<0.02
0.004
<1
<0.01
0.02
0.5
<0.001
<10
<0.04
0.003
140
<0.02
0.051
<1
<0.01
0.04
0.4
0.0012
<10
<0.04
0.003
Hi-speed
magnetic stir
<0.03
0.135
<1
0.014
0.2
1.0
<0.001
<10
0.16
0.005
10 x DWS
(NIPEWR
1976)
0.5
0.5
10.0
0.1
0.5
14 to
24
0.02
100.0
0.5
0.1
"Exceed 10 x DWS
-------
Table 6
SPECIFIC CONDUCTANCE (milliraho/cm) OF TEP EXTRACTANT
Agitation, excursions/min
Sample
Extraction
70
88
I
108
140
Hi-Speed
Magnetic Stir
Battelle Bed
1st - 24 hr
11.90
17.2
24.10
24.6
14.9
2nd - 24 hr
9.72
9.89
7.49
4.5
5.32
Final mix
10.80
13.0
17.0
18.1
17.7
Argonne Bed
1st - 24 hr
6.26
9.93
16.7
18.4
28.1
2nd - 24 hr
5.56
8.87
13.2
17.4
6.27
Final mix
5.64
8.79
13.9
17.9
20.8
-------
Table 7
TOTAL VOLUME (ra£) OF 1:1 ACETIC ACID REQUIRED TO ACHIEVE pH = 5
Agitation, excursions/min
Sample
Extraction
70
88
108
140
Hi-Speed
Magnetic Stir
Battelle Bed
1st - 24 hr
16.0
26.4
49.2
51.1
59.1
2nd - 24 hr
10.4
10.7
6.2
3.5
1.9
Total
26.4
37.1
55.4
54.6
61.0
Argonne Bed
1st - 24 hr
5.7
11.4
24.3
29.4
75.0
2nd - 24 hr
4.1
8.7
16.4
25.0
2.8
Total
9.8
20.1
40.7
54.4
77.8
-------
4. KKI-'K RENCES
1. Resource Conservation and Recovery Act, Public Law 94-580; 19 7b.
2. Strategy for the Implementation of the Resource Conservation and
Recovery Act of 1976 (draft), U.S. Environmental Protection Agency;
December 5, 1977.
3. Hazardous Waste Guidelines and Regulations - Criteria, Identifica-
tion, and Listing of Hazardous Waste, U.S. Environmental Protection
Agency, 40 CFR 250 (draft); September 12, 1978.
4. Viviani, D. , EPA Hazardous Waste Management Division, Visit to
Westinghouse, August 3, 1978.
5. Friedman, D. , D. Viviani and A. Corson, EPA Hazardous Waste Manage-
ment Division, Private communication; 1978.
6. Mr. Varouxis, Associated Design and Manufacturing Company, Private
communication; October 1978.
7. Arora, H., Oak Ridge National Laboratories, Private communication;
October 1978.
74
-------
APPENDIX B
EPA INTERIM PRIMARY AND SECONDARY DRINKING WATER STANDARDS*
Parameter Maximum Level
A. Interim primary (mg/Jl)
Arsenic 0.05
Barium 1.0
Cadmium 0.01
Chromium (VI) 0.05
Fluoride 1.4-2.4
Lead 0.05
Mercury 0.002
Nitrate (as N) 10
Selenium ...... 0.01
Silver 0.05
Endrin ............ 0.002
Lindane 0.004
Methoxychlor 0.1
Toxaphene 0.005
2.4-D 0.01
2.4.5-TP Silvez (sic) 0.01
Radium 5 pCi/1
Gross Alpha 15 pCi/1
Gross Beta 4 millirem/yr
Turbidity 1/TU
Coliform Bacteria 4/100 ml
B. Secondary (mg/Jl)
Chloride 250
Copper 1
Foaming Agents 0.5
Iron 0.3
Manganese 0.05
Sulfate 250
TDS 500
Zinc 5
Color 15 Color Units
Odor 3 Threshold Order
Number
PH 6.5-8.5
~Source: Federal Register, 43 (243); December 18, 1978.
75
-------
APPENDIX C
CHEMICAL CHARACTERIZATION OF RESIDUE SAMPLES
This appendix presents the solid compositions of those sample cate-
gories investigated under RCRA tests (Table 5 of text). In most cases
data of the particular samples used for the RCRA/EP test are presented.
In addition to the chemical compositions of solids prior to leaching,
leachate characteristics obtained by using the Westinghouse screening
tests - the 200-hr continuous shake method using three leaching media,
i.e., deionized water, CO2 - saturated water, and acetate buffer - are
also summarized in these tables. The data presented here provide useful
background for understanding and interpreting the RCRA test results. A
detailed description of the solid residue study Westinghouse had carried
out since 1974 can be found in our previous reports.
76
-------
REFERENCES
1. Sun, C. C., C. H. Peterson, R. A. Newby, W. G. Vaux, and
D. L. Keairns, Disposal of Solid Residue from Fluidized-Bed Com-
bustion: Engineering and Laboratory Studies, report to EPA, West-
inghouse Research and Development Center, Pittsburgh, PA, March
1978, EPA 600/7-78-049, NTIS PB 283-082/6ST.
2. Sun, C. C., C. H. Peterson, and D. L. Keairns, Experimental/
Engineering Support for EPA's FBC Program: Final Report, Volume 3,
Solid Residue Study, report to EPA, Westinghouse Research and
Development Center, Pittsburgh, PA, January 1980, EPA 600/7-
80-015C.
3. Keairns, D. L., et al., Fluidized Bed Combustion Process Evalua-
tion, Phase Il-Pressurized Fluidized Bed Coal Combustion Develop-
ment, report to EPA, Westinghouse Research and Development Center,
September 1975, EPA-650/2-75-027c, NTIS PB 246-116.
4. Advanced Coal Gasification System for Electric Power Generation,
Quarterly Progress Report to U.S. Department of Energy, Westing-
house Electric Corporation Advanced Coal Conversion Department,
Madison, PA, January 1980, Contract EF-77-C-01-1514.
77
-------
Table C-l
SOLID AND LEACHATE CHARACTERISTICS OF MERC-AFBC RESIDUES
(200-hr Continuous Shake Tests)
Substance
Solid,ppma
11)
(21
(3)
Major
Major
Major
<1
<1
1000 f >1000
220 \ 280
10 . I 10
>1000
70
100
<33
<0.01
>1000
>1000
<0.04
<0.04
<0.04
<0.04
<0.01
<0.02
1000
<0.05
co,Di
<0.05
< a 05
-------
Table C-2
0*9- 17MB67
SOLID AND LEACHATE CHARACTERISTICS OF PER-AF3C CYCLONE CARRY-OVER
MATERIAL, RUN 704-14, WITHOUT CARBON BURN-UP CELL (CBC)
(200-hr Continuous Shake Tests)
Substance
Solid,
ppm
Leachate
Deionized
H20, mg It
Leachate
Acetic
Buffer,
mg/Z
DWS.
mg//
Al
4.58%
<1
<1
Aq
<1
<0.02
<0.02
0.05
As
<0.001
<0.001
0.05
B
70
<1
<1
Ba
700
<1
<1
1.0
Be
7
<0.03
<0.03
Bi
5
<0.1
<0.1
Ca
11.2*
mm/A
2736
200
Cd
<10
<0.005
<0.005
0,01
Co
<30
<0.1
<0.1
Cr
100
<0.05
<0.05
0.05
Cu
100
<1
<1
1.0
Fe
5.56%
<0.3
<0.3
0.3
Ga
20
<0.03
<0.03
Ge
20
<0.1
<0.1
Hg
0.0013
0.0016
0.002
K
0.85%
Mq
0.38%
<10
14.4
150
Mn
500
<0.03
<0.03
0.05
Mo
20
0.1
0.1
Na
0.082%
Ni
50
<1
<1
2.0
Pb
10
<0.05
<0.05
0.05
Sb
<30
<3
<3
Sfi
<0.001
<0.001
0.01
Si
10.3%
<5
<5
Sn
<10
<0.1
<0.1
1.0
Sr
500
3
7
Ti
>1000
<1
<1
V
100
<0.1
<0.1
Zn
200
<3
<3
5.0
Zr
100
<1
< 1
SO3
SO4
6.9%
v//mw//a
1
§
1
250
S"
0.01%
11.4
13.7
F
1
0°
Os
<1
2.4
CI
4000
100
250
NO3 (as N)
<1
< 1
10
PO4
<1
<1
TOC
<5
PH
tfV
OO1
VZ/AW///,
6.5 to 9.2
SC. umholcm
8010
12500
-750
DWS - NIPDWR, USPHS, and WHO Drinking Water Standards
Exceeds DWS
79
-------
Table C-3
.iwg . 7 MB69
SOLID AND L15ACHATE CHARACTERISTICS OF PFBC-EXXON CARRY-OVER,
RUN 105 WITH SORBENT REGENERATION
(200-hr Continuous Shake Test)
Substance
Solid,
opm
Leachate
Deionized
HjO, mgU
Leachate
Acetic
Buffer,
mg/J
DWS.
ng //
Al
4.22%
<1
<1
Aq
< 1
< 0.92
<0.02
0.05
As
<0.001
<0.001
0.05
B
200
<1
<1
Ba
500
<1
<1
1 0
Be
1
<0.03
<0.03
Bi
5
<0.1
<0.1
Ca
22. 3%
y////x®y//A
2632
200
Cd
< 10
<0.005
<0.005
0.01
Co
<30
<0.1
<0.1
Cr
100
0.05
0.1
0.05
Cu
33
<1
<1
1.0
Fe
5. 95%
<0.3
<0.3
0.3
03
20
<0.03
<0.03
Ge
<10
<0.1
<0.1
Hq
0.0012
0.0014
0.002
K
0. 23%
Mci
0.91%
<10
19.2
150
Mn
500
<0.03
<0.03
0.05
Mo
20
0.1
0.1
Na
0. 28%
Ni
50
<1
<1
2.0
Pb
10
<0.05
<0.05
0.05
Sb
<30
<3
<3
Se
0.003
<0.001
0.01
Si
r 10.8%
<5
<5
Sn
<10
<0. 1
<0.1
1.0
Sr
500
4
7
Ti
>1000
<1
<1
V
100
<0.1
<0.1
Zn
300
<3
<3
5.0
Zr
100
<1
<1
S03
S04
6.1%
V///AW///A
y////»r////.
250
S =
0.027%
<10
10.6
F
2.4
1
2.4
CI
'////AW/A
100
250
NO3 (as N)
<1
<1
10
<1
<1
TOC
<5
dH
y//A\'i<)y///.
V//Am///y
6.5 to 9.2
SC, unnho/'cm
8.430
13.400
-750
OWS - NIPDWR, USPHS, and WHO Drinking Water Standards
Exceeds DWS
80
-------
Table C-4
t>«9. 2624C93
CHEMICAL CHARACTERISTICS OF SOLID AND
LEACHATE FROM EXXON 73 RESIDUE
(200-hr Continuous Shake Test)
—
Exxon 73 Bed Stone
Exxon 73 2nd Cyclone
Exxon 73 3rd (vt lone
Substance
Solid,
ppm
Leachate
Oeionized
H^O. mgtl
Leachate
Acetic Butter,
mg//
Solid,
ppm
Leachate
Deionized
H?0. mg/J
Leachate
Acetic Buffer,
mg 11
Solid,
ppm
Leachate
Deionimt
H?0. mg ft
leachate
Acetic Buffer,
mg It
DWS.
mg/l
-¦
. Al
Ag
As
B
Ba
Be
Bi
Ca
.. Cd
Co
Cr
1,33*
•: 1
200
' " J
•: 1
22,56%
<• a
<5
150
^ <1
<0.01
<0,001
1
< 1
< o,6a
< 0>01
<0,01
< 0.03
0,02
<0,1
<0.01
* 0,001
3
<1
<0,01
< 0v0i
'.V.'^896"V;r;
< 0.01
<0.1
<0.03
3%
< 1
200
2
< 1
18.4ft
<33
10
150
<1
<0.01
<0,001
0.2
< 1
<0,01
<0.01
<0.01
<0.03
0. 02"
<0.1
<0.01
< 0.001
3
" 3
N 10
Ti
300
sQJ
.iil
1.000
<0.1
<0.1
1000
<0.1
0.06
<0.1
0.03
V
40
<0.01
<0.03
50
<0.01
<0.03
90
r-
Zn
< 50
< 1
< i
<50
<1
<1
50 ^
< 1
V 1
5 0
It
< 10
<0.2
<0.2
30
<0.2
<0.2
50
SY
•29%
1,380
//
830 1
26.34%
^ 1.040 '
24.79%
1.667
i.150
?50
...
S =
f
0.073%
<10
<10
<1
0.067%
__ _
-------
Table C-5
CHEMICAL CHARACTERISTICS OF SOLID AND LEACHATE
FROM LEATHERHEAD, AEP TEST 7 RESIDUE
(200-hr Continuous Shake Test)
Dwg. 2624C92
Leatherhead Primary Ash
Leatherhead Secondary Asfi
leachate
Leachate
Leachate
Leachate
Solid.
Deionized
Acetic Buffer,
Solid.
Deionized
Acetic Buffer.
DWS,
Substance
ppm
H.,0. mq/t
mq/|
ppm
H^O, mg//
mg//
mg//
a!
3. S*.
< 1
<0.1
9.94?.
< 1
< 0.01
Ag
As
< 1
<0.01
0.001
<0.01
0.004
<1
<0.01
0.013
<0.01
0.011
0.05
0.05
b"
200
-^0.1
I
200 ' ]
<0.1
10
Ba
< ]
< 1
< r
< 1
1.0
Be
?
¦ 0.01
< 0.1
10
0.01
<0.01
Bi
< 1
< 0.01
<0.01
< 1
<0.01
< 0.01
Ca
14.56%
' 680
2.040 '
3.81*
" ,* "640"
" '"l'088'
200
Cd
< 33
< 0.01"
< 0.01
< 33
3
5
Ti
-• 1,000
< 0.1
<0.1
<1.000
<0.1
<0.1
V
60
0.01
<0.03
150
0.1
O.l
lr\
50
< 1
<1
50
<1
< 1
5.0
Zr
100
>
<0.2
< 10
100
<0.2
<0.2
S04
12.36%
V.'mo,"
j.m
250
S=
0.05V.
'* '< 10 " '' *
0.05%
< 10
<10
F
CI
29
< 1
15
J
<1
4
2.4
250
NOjtas N)
TOC
< 1
<1
<1
< 1
10
• 10
< 10 '
PH
SC (umho/cm)
. n:\8Z '/
8.59
7^%W///Z
8.57
Y/7.^y ¦
6.5109.2
- 750
DWS - NIPDWR. US MS. and WHO Drinking Water Standards
I.. : T1 Exceeds DWS
82
-------
Table C-6
SOLID AND LEACHATE CHARACTERISTICS OF PFBC-EXXON COMBUSTOR BED
RESIDUE, RUN 105 WITH SORBENT REGENERATION
(200-hr Continuous Shake Test)
Substance
Solid,
ppm
Leachate
Deion ized
H2O, mg/i
Leachate
Acetic
Buffer,
mg it
DWS
mg !£
Al
1.38%
< 1
< 1
Ag
<1
<0.03
<0.03
0.05
As
<0.001
<0.003
0,05
B
330
30
100
Ba
200
<1
< 1
1.0
Be
3
<0.03
<0.03
Bi
100
<0.1
<0.1
Ca
39.5?%
V///.W7//A
3004
200
Cd
<10
<0.005
<0.005
0.01
Co
<30
<0.1
<0.1
Cr
100
0.02
0.02
0.05
Cu
33
<0.1
<0.1
1.0
Fe
1.24%
<0.3
<0.3
0.3
Ga
20
0.5
1
Ge
20
<0.1
<0.1
Hg
0.0012
0.001
0.002
K
0.22%
Mq
0.28%
12
0
150
(Vn
100
<0.03
<0.03
0.05
Mo
10
0.1
0.1
Na
0.063%
M
55
<0.1
0.1
2.0
Pb
10
<0.05
<0.05
0.05
Sb
<30
<1
<1
Se
<0.002
<0.002
0.01
Si
2.93%
<3
<3
Sn
<10
<0.1
<0.1
1.0
Sr
300
<5
<5
Ti
>1000
<1
<1
V
100
<0.1
<0.1
Zn
300
<5
<5
5.0
Zr
30
<1
<1
SO3
SO4
51.78%
Y//AZIW///
|
|
250
S =
0.016*
<2
<10
F
msy/m
<1
2.4
CI
20
45
250
N03
-------
Table C-7
Dwj .
SOLID AND LEACHATE CHARACTERISTICS OF PFBC-EXXON CARRY-OVER,
RUN 105 WITH SORBENT REGENERATION
(200-hr Continuous Shake Test)
Substance
Second Cyclone
Third Cyclone
Solid,
ppm
Leach ate
Deionized
H^O, mg\£
Leachate
Acetic
Buffer,
mg//
Solid
ppm
Leachate
Deionized
H2O, mg 11
Leachate
Acetic
Buffer,
mgi#
DWS,
mg ii
Al
8.09%
<1
1
<1
< 'J. 03
9.09%
1000
<1
< 1
>1000
<1
< 1
V
100
0.1
0.5
100
0.6
0.1
Zn
300
<5
<5
300
<5
<5
5.0
Zr
70
<1
<1
70
<1
< 1
S03
~ SO4
17.9%
m®y/A
'/aw///,.
15.8%
'//A*W/A
VAW//A
250
S ~
0.016ft
<5
<5
<0.01%
<2
0
E
1.5
2.2
2.2
1.4
2.4
_CI
25
20
*?
250
NO3 las N)
<1
< 1
<1
<1
10
rar
TOC
<1
< 1
< 1
< 1
<5
< 5
PH
SC, pinho/cm
V/MW/a
///A/'-jcV/V
V//P.- 7Y///
9.1
6.1
6.5 to 9.2
Y//Wm
9850
vmy//,
V/?W//A
- 750
DWS - NIPDWR, USPHS, and WHO Drinking Water Standards
Exceeds DWS
84
-------
Table C-8
wV«g . 1 ^' 4B6b
SOLID AND LEACHATE CHARACTERISTICS OF PFBC-EXXON
REGENERATOR BED AND CARRY-OVER, RUN 105
(200-hr Continuous Shake Test)
Substance
Regenerator Bed
Regenerator Carry-over
DWS,
mg/2
Solid,
ppm
Leachate
Deionized
H2O, mg\i
Leachate
Deion ized
H2O, mg/i
Anaerobic
Solid,
ppm
Leachate
Deionized
H2O, mgII
Leachate
Acetic
Buffer,
mg il
Al
4.07%
<1
<1
4.92%
< 1
<1
Ag
<1
<0.02
<0.02
<1
<0.03
<0.03
0.05
As
<0.001
<0.001
<0,00!
<0.001
0.05
B
300
<1
< 1
800
36
100
Ba
500
< 1
< 1
300
< 1
1
1.0
Be
3
<0.03
<0.03
5
<0.03
<0.03
Bi
3
<0.33
<0.33
70
<0.1
<0.1
Ca
42.8%
V/W//A.
y////mv/A
29.4%
¦///Amy/,
2840
200
Cd
<10
<0.01
<0.01
<10
<0.005
<0.005
0.01
Co
<30
<0.1
<0.1
<30
<0.1
<0.1
Cr
<10
V//,.W//z
y////xw/A
100
<0.02
<0.02
0.05
Cu
10
< 1
<1
100
< 1
< 1
1.0
Fe
4.75%
<0.3
<0.3
8.48%
<0.3
<0.3
0.3
Gd
30
<0.1
<0.1
30
3
0,5
Ge
10
<0.1
<0.1
30
<0.1
<0.1
Hq
0.0015
0.0014
0.0014
0.0014
0.002
K
0.43%
0.32%
Mq
1.1%
< 10
19.2
L05%
<3
<10
150
Mn
300
<0.03
<0.03
150
<0.03
<0.03
0.05
Mo
10
<0.1
<0.1
20
0.33
0.33
Na
0.078%
0.075%
2.0
Ni
50
<1
<1
50
<0.1
<0.1
Pb
<10
<0.01
<0.01
<10
<0.05
<0.05
0.05
Sb
<30
<1
<1
<30
< 1
<1
Se
0.002
0.001
0.003
0.002
0.01
Si
7.99%
<5
<5
7.74%
<3
<3
Sn
<10
<0.1
<0.1
<10
<0.1
<0.1
1.0
Sr
1
O
O
<5
<5
500
5
5
Ti
>1000
<1
< 1
>1000
<1
<1
V
100
<0.1
<0.1
100
<0.1
<0.1
Zn
100
<3
<3
300
<3
<3
5.0
7.r
100
<1
<1
70
<1
<1
503
SOi
9.74%
y/zvpy/A
'AAAA\l&AAA/
7.88%
AAsMi'AA
YAAmAAA
250
S =
0.05%
19.7
80.5
0.096%
106.4
99.5
F
y////^y/z
'VMiS'/A
<1
1.8
2.4
CI
\2
P
250
250
NO3 (as N)
<1
<1
V
7
10
PO4
<1
<1
<1
<1
TOC
<5
6
<5
PH
y//AVY//,
V///AW///
y//Ain/A
1
' I—•
1
6.5 to 9.2
SC, pmhoicm
10,120
10.170
8.320
15.200
~ 750
DWS - MPDWR, USPHS, and WHO Drinking Water Standards
V////A Exceeds DWS
85
-------
Table C-9
Ov/a. 1 7 09 R 92
SOLID AND LEACHATE CHARACTERISTICS OF ADIABATIC PFBC
BAGHOUSE RESIDUE FOR COMBUSTION POWER CP-403 RUN
(200-hr Continuous Shake Test")
Substance
Solid,
ppm
Leachate.
mg /£
a
DWS.
mg U
Al
Major
2
Aq
<1
<0.01
a 05
As
<0.003
a 05
B
500
>5
Ba
<1
L0
Be
<0.01
Bi
<10
<0.01
Ca
16%
Z/A%/A
200
Cd
<3
<0.01
a 01
Co
15
<0.01
Cr
100
<0.02
0.05
Cu
100
<0.05
1.0
Fe
Major
<0.05
0.3
Hq
<0.002
0.002
Mg
8.7%
0
150
Mn
220
<0.01
0.05
Mo
50
0.2
Na
>1,000
>5
Ni
80
<0.05
2.0
Pb
50
< a 01
a 05
Sb
<33
4
Sn
<10
<0.01
L0
Sr
100
> 10
Ti
>1,000
<0.05
V
60
0.02
Zn
150
<1
5.0
Zr
<1
SO4
ia 5%
VAW/s
250
S=
0.02*
<5
TOC
<10
dH
V/& i//
6.5 to 9.2
SC, Mmho/cm
"/A-vr/,
-750
a
DWS - NIPDWR, USPHS, and WHO drinking water standards
^ exceeds DWS
oo
-------
Table C-10
0*9. A18C35
CHEMICAL CHARACTERISTICS OF FGD SLUDGE, LIQUOR, AND LEACHATE3
LMcntfe Irom dried solids, ppm
lifter 200-hr continuous shake)
liquor, ppm
Sludge, ppm
(on dry basis)
Substances
Untreated
Ponded
Oxidized
Untreated
Ponded
Oxidized
Stabilized
<0.01
30 to 300
Oto 2
10 to 1000
Oto 15
< a oi
1000
OToTO
0to6p0j7
'yxiY///^
1000
Oto 100
-------
Table C-ll
Dwg. 2626C28
SOLID AND LEACHATE CHARACTERISTICS OF
CONVENTIONAL FLY ASH SAMPLES
(200-hr Shake Test)
Substance
F1y Ash No 1
F 1 y Ash No. 2
0WS,
m}/£
Sol id,
ppm
Leachate:
De ion 1 zed
HjO.mg//
Leachate '•
Acetate
Buf fer, mg/-i
So 1 1 d,
ppm
Leochate
De 1 on i zed
H^O. mg/J
Leachate:
Acetate
Buf fer, mg/^
A1
11,8*
0.2
3
10.58%
<1
1
Ag
<1
<0.02
<0.02
<1
<0.01
<0.01
0.05
As
v/ww/
0.005
0.021
0.05
B
150
5
25
300
>1
>10
Ba
600
<1
<1
<1
<1
1.0
Be
3
<0.01
<0.01
8
<0.01
<0.01
Bi
<10
<0.01
<0.01
<1
<0.01
<0.01
Ca
1.8%
192
xrnrm
2.08%
WM'fM
mm///,
200
Cd
<5
<0.005
<0.005
<33
<0.01
<0.01
0.01
Co
<10
<0.02
<0.02
5
<0.02
<0.1
Cr
150
<0.02
<0.02
60
WW//,
0.05
Cu
100
<0. 1
<0. 1
10
<0.1
<0.1
1.0
Fe
9.2%
<0.02
<0.3
10.68%
0.1
m///////
0.3
Ge
5
30
0.01
0.03
Hg
0.0009
0.0009
30
0.0009
0.0013
0.002
Li
300
0.01
0.2
K
1 .6%
1.15%
Mg
0.096%
4.8
52.8
0.38%
<5
1 15
150
Mn
1000
<0.01
200
<0.01
0.05
Mo
30
0. 1
0.8
<30
0.3
0.5
No
0.62*
>1
Major
0.55%
»l
»I0
Ni
80
<0.05
0.08
60
<0.05
0.2
2.0
Pb
50
<0.04
<0.04
40
<0.01
<0.03
0 05
Sb
<50
<0. 1
<0.1
<50
<0.05
<0.1
Se
y//m////,
0.004
0.01
Si
30. 1%
2
<10
20.25%
Sn
<10
<0.1
<0.1
<10
<0.05
<0.1
1 .0
Sr
>1
>10
1000
>1
10
Ti
>1000
<0.1
<0.1
>1000
<1
<1
V
50
<0.02
0.08
150
0. 1
0.1
Zn
100
<1
2
100
<1
<1
5.0
Zr
300
<0.5
<0.5
500
<1
<1
S03
1.3%
S04
0.65%
Wf&W/,
AN
1
3.58%
WW/////,.
///*&//////
250
S*
0.04%
0
0
0.06%
<5
<5
F
<1
<1
<1
<1
2.4
CI
2
<1
2
<1
250
Br
<1
<1
NO3 (as N)
<1
<1
<1
<1
10
P04
<1
<1
Unburned C
10%
7%
TOC
<10
<10
PH
7.88
i'ti///
y/,w/////A
6.5 to 9.2
SC f mho/cm
WMm
Z/,n<*///A
~750
OWSNIPDWR and WHO Drinking Hater Standard*
Exceed, DNS
Exceeds 10 x DWS
88
-------
Table C-12
Dwg. 2626C29
SOLID AND LEACHATE CHARACTERISTICS OK
CONVENTIONAL BOTTOM ASH SAMPLES
(200-hr Shake Test)
Substance
Bottom Ash No.l
Bottom Ash No.2
DHS,
rry/ /
Sol id,
ppm
Leachate:
De i on ized
H2O, rng/i
Leachate:
Acetate
Buffer, mg/^
Sol id,
ppm
Leachate:
Oe i on i zed
HjO.mg/J
Leachate:
Acetate
3uf fer, m4
8.05%
<1
>6
*9
<1
<0.01
<0.01
<1
<0.01
<0.01
0.05
As
0.005
<0.001
0.012
0.003
0.05
8
200
1
3
200
1
4
Bo
<1
<1
<1
<1
1 .0
Be
5
3
<0.01
<0.01
Bi
<1
<0.01
<0.01
<1
<0.01
<0.01
Co
<1.28%
<5
<5
1.92%
172
WW////A
200
Cd
<33
<0.01
<0.01
<33
0.01
<0.02
0.01
Co
10
<0.1
<0.1
10
<0.1
<0.1
Cr
110
<0.02
0,02
120
<0.02
/^////A
0.05
Co
10
<0.1
V//AV///Z
20
<0.1
<0.1
1 .0
Fe
21.98%
0.2
'//AY////.
13.02%
W/////A
VA'/////M
0.3
Go
<3
0*05
4
3
0.2
<0.03
Ge
<3
<0.05
<0.05
<3
<0.02
<0.03
Hg
0.0013
0.0015
0.0008
0.0012
0.002
K
1.37%
1.16%
Mg
<5
<10
0.192%
<10
26.4
150
Mil
200
0.04
y/&r/////z.
200
'{AW/////
0.05
Mo
<30
<0.05
<0.05
<30
<0.1
<0.1
Na
0.39*
0.37%
7
»6
Ni
20
<0.04
<0.04
30
0.07
0.2
2.0
Pb
<10
'//&1000
<0 .5
<0 .5
>1000
<1
<1
V
BO
<0.05
<0.05
60
<0.02
0.03
Zn
50
<1
<1
50
<1
<1
5.0
Zr
500
<1
<1
500
<1
<1
SO*
<1
<1
^4
0.026%
17
<10
1.247%
V/i\&/////,
245
250
S"
0.027%
<10
<10
0.041%
<5
<10
F
<1
<1
<1
<1
2.4
C'
<1
1.6
3
1
250
Br
NOz
<1
<1
fat N)
<1
<1
<1
<1
10
P04
<1
<1
TOC
<10
00
P*
7.5
1
i
7.8
VAw/m
6.5 to 9.2
SC , «nno s*
S3
V/??®'///*
1
1
'/.*sta>7///
—750
QMS - NtPDOT and WHO Drinking Water Standards
I'////////* Exceeds DHS
rXYYX^ ixceeds 10 * DWS
89
-------
APPENDIX D
RCRA EXTRACTION PROCEDURE (43 FR 58956)
(A) EQUIPMENT
(I) An agitator which, while preventing stratification of sample
and extraction fluid, also insures that all sample surfaces
are continuously brought into contact with well-mixed extrac-
tion fluid.
(II) Equipment suitable for maintaining the pH of the extraction
medium at a selected value.
(B) PROCEDURE
(I) Take a representative sample (minimum size 100 g) of the waste
to be tested. Separate sample into liquid and solid phases.
The solid phase is defined as that fraction which does not
pass through a 0.45-pm filter medium under the influence of
either pressure, vacuum, or centrifugal force. Reserve the
liquid fraction under refrigeration (1-5°C) for further use.
(II) The solid portion of the sample, resulting from the separation
procedure above or the waste itself (if it is already dry),
shall be prepared either by grinding to pass through a 9.5-mm
(3/8 in ) standard sieve or by subjecting it to the structural
integrity procedure.
(Ill) Add the solid material from Paragraph II to 16 times its
weight of deionized water. This water should include any
water used during transfer operations. Begin agitation and
extract the solid for 24 t 0.5 h. Adjust the solution to pH 5
90
-------
and maintain that pH daring the course of the extraction using
0.5 N acetic acid. If more than 4 ml of acid for each g of
solid would be required to maintain the pH at 5, then once
4 ml per g of solid has been added, complete the 24-h extrac-
tion without adding any additional acid. Maintain the sample
between 20-40°C during extraction.
(IV) At the end of the 24-h extraction period, separate the sample
into solid and liquid phases as in Paragraph I. Adjust the
liquid phase with deionized water so that its volume is
20 times that occupied by a quantity of water at 4aC equal in
weight to the initial sample of solid (e.g., for an initial
sample of 1 g, dilute to 20 ml). Combine this liquid with the
original liquid phase of the waste. This combined liquid,
including precipitate which later forms from it, is the
Extraction Procedure extract.
91
------- |