BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT)
BACKGROUND DOCUMENT FOR
ORGANOPHOSPHOROUS WASTES
Robert April, Chief
Treatment Technology Section
Mary Cunningham
Project Manager
U.S. Environmental Protection Agency
Office of Sol id Waste
401 M Street, S.W.
Washington, D.C. 20460
June 1989
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ACKNOWLEDGMENTS
This document was prepared by the U.S. Environmental Protection
Agency, Office of Solid Waste, with the assistance of Versar Inc. under
Contract No. 68-01-7053. Mr. Robert April, Acting Chief, Treatment
Technology Section, Waste Treatment Branch, served as the EPA Program
Manager during the preparation of this document and the development of
treatment standards for the organophosphorous wastes. The technical
project officer for the waste was Ms. Mary Cunningham. Mr. Steven
Silverman served as legal advisor.
Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Program Manager; Mr. Stephen Schwartz, Task
Manager; Ms. Josephina Castellanos, Staff Engineer; Ms. Barbara Malczak,
Technical Editor; and Ms. Sally Gravely, Project Secretary.
Th§ Agency wishes to thank Monsanto for submitting data on the
treatment of Parathion.
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TABLE OF CONTENTS
Section Page
1. INTRODUCTION ! 1-1
2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industry Affected and Process Description 2-1
2.2 Waste Characterization 2-3
2.3 Determination of Waste Treatability Group 2-8
3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.2 Demonstrated Treatment Technologies 3-3
4. PERFORMANCE DATA BASE 4-1
5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY.... 5-1
5.1 Nonwastewaters 5-2
5.2 Wastewaters 5-3
6. SELECTION OF REGULATED CONSTITUENTS 5-1
6.1 Identification of BDAT List Constituents 6-1
6.2 Constituent Selection 6-2
7. DEVELOPMENT OF BDAT TREATMENT STANDARDS 7-1
8. REFERENCES 8-1
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LIST OF TABLES
Table Page
1-1 Treatment Standards for the Organophosphorous Wastes .... 1-4
2-1 Number of Facilities and Volume of Organophosphorous
P and U Wastes Generated in 1986 2-6
2-2 Available Characterization Data for K038 2-7
2-3 Available Characterization Data for K039 2-8
2-4 Available Characterization Data for K040 2-9
4-1 Biological Treatment for Parathion 4-5
6-1 Waste Characteristics Affecting Performance of
Incineration 6-4
6-2 Regulated Constituents for K038, K039, and K040 6-4
7-1 BOAT Nonwastewater Treatment Standards for K038 and K040. 7-3
7-2 BOAT Wastewater Treatment Standards for K038 and K040 ... 7-4
i v
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LIST OF FIGURES
Figures Page
2-1 Phorate Production 2-5
2-2 Chemical Structures for P and U Wastes 2-12
4-1 Phorate Chemical Structure 4-3
4-2 Disulfoton Chemical Structure 4-3
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1. INTRODUCTION
Pursuant to section 3004(m) of the Resource Conservation and Recovery
Act (RCRA) as enacted by the Hazardous and Solid Waste Amendments (HSWA)
on November 8, 1984, the Environmental Protection Agency (EPA) is
establishing treatment standards based on the best demonstrated available
technology (BDAT) for the waste treatability group identified as
organophosphorous wastes. These wastes are identified in 40 CFR 261.32
as K038, K039, and K040; in 40 CFR 261.33, they are identified as P039,
P040, P041, P043, P044, P062, P071, P085, P089, P094, P097, P109, Pill.
U058. U087, and U235. The Agency is also establishing standards for the
wastewater forms of K036. A treatment standard of "No Land Disposal
Based on No Generation" was promulgated for the nonwastewater forms of
K036 on August 8, 1988. EPA amended this standard to apply only to
wastes generated from a process meeting the listing description and
disposed of after August 17, 1988 (54 FR 18836 - May 2, 1989).
Compliance with these BDAT treatment standards is a prerequisite for the
placement of these wastes in land disposal units. The effective date of
these treatment standards is June 8, 1989.
This background document provides the Agency's technical support for
selecting and developing treatment standards for the constituents to be
regulated in these organophosphorous wastes.
n
l-i
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The principal constituents of concern in each of these wastes are
members of a group of organic compounds known as organophosphorous
compounds. The majority of these constituents also contain sulfur and
are often referred to 'as phosphorothioates. All of these compounds are
somewhat similar in structure and elemental content. Most are typically
manufactured for use as pesticides. Therefore, the Agency has classified
all of these compounds as one treatability group identified as the
organophosphorous pesticides.
Section 2 presents waste-specific information — the number and
location of facilities affected by the land disposal restrictions, the
waste-generating process, and the waste characterization data. Section 3
discusses the applicable and demonstrated technologies used to treat
these wastes (or similar wastes). Section 4 presents the available
performance data, including data on which the treatment standards are
based. Section 5 explains EPA's determination of BDAT, while Section 6
discusses the selection of constituents to be regulated and Section 7
presents treatment standards for these constituents.
The BDAT program and promulgated methodology are more thoroughly
described in 'two additional documents: Methodology for Developing BDAT
Treatment Standards (USEPA 1988c) and Generic Quality Assurance Project
Plan for Land Disposal Restrictions Program ("BDAT") (USEPA 1987). The
petition process that must be followed when requesting a variance from
the BDAT treatment standards is discussed in the methodology document.
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For the purpose of determining the applicability of the treatment
standards, wastewaters are defined as wastes containing less than
1 percent (weight basis) total suspended solids* and less than 1 percent
(weight basis) total organic carbon (TOC). Wastes not meeting this
definition must comply with the treatment standards for nonwastewaters.
The Agency is promulgating numerical performance standards for
Disulfoton in K036 wastewaters and in P039 wastewaters and
nonwastewaters; Phorate in K038, K040, and P094 wastewaters and
nonwastewaters; and Methyl Parathion, Parathion, Famphur, and
tris-(2,3-dibromopropyl) phosphate in P071, P089, P097, and U235
wastewaters and nonwastewaters, respectively. If the concentrations of
the regulated constituents, as generated, are lower than or equal to the
BDAT treatment standards, then treatment is not necessary as a
prerequisite to land disposal. The treatment standards for the
wastewater forms of these wastes are based on transfer of biological
treatment data received during the comment period for the Second Third
wastes proposed treatment standards; and the treatment standards for the
nonwastewater forms are based on a transfer from the incineration
performance data for K037.
* The term "total suspended solids" (TSS) clarifies EPA's previously used
terminology of "total solids" and "filterable solids." Specifically,
total suspended solids is measured by Method 209c (Total Suspended
Solids Dried at 103 to 105°C) in Standard Methods for the
Examination of Water and Wastewater (APHA, AWWA, and WPCF 1985).
£7?5>g
1-3
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In addition, the Agency is setting technology-based BDAT standards
for the wastewater and nonwastewater forms of K039, P040, P041, P043,
P044, P062, P085, P109, Pill, U058, and U087, requiring that specific
treatment technologies be used to treat the wastes. The treatment
standard for the wastewater forms of these wastes requires that
incineration or carbon adsorption followed by incineration be used. The
treatment standard for the nonwastewater forms of these wastes requires
incineration as a treatment technology.
Table 1-1 presents the treatment standards for the organophosphorous
wastes.
lUzr,
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231 Sg
Table 1-1 (redtment Standards for the Organophosphorous Wastes
Waste
code
Regu lated
constituent
Wastewaters
(PP">)
Nonvastevaters
(PP»)
PC036
K.038
K.039
K040
P039
P040
P041
P043
P044
P062
P071
P085
P089
P094
P097
PI 09
Pill
uosa
U087
U23S
Oisulfoton
Phorate
Phorate
0isulfoton
Methyl parathion
d
Parathion
Phorate
Faflvhur
f r ts-(?.3-
OiDromopropy1)
phosphate
0.025
0.025
Cartoon adsorption
or incineration
0.025
0.0ZS
Carbon adsorption
or incineration
Carbon adsorption
or incineration
Carbon adsorption
or incineration
Carbon adsorption
or incineration
Carbon adsorption
or incineration
0.025
Carbon adsorption
or incineration
0.025
0.025
0.025
Carbon adsorption
or incineration
Carbon adsorption
or incineration
Carbon adsorption
or incineration
Carbon adsorption
or incineration
0 025
0.10
lncineration
0.10
0.10
lncineration
Incineration
lncineration
Incineration
Incineration
0.10
lncineration
0.10
0.10
0.10
lncineration
lncineration
lncineration
Incinerat ion
0.10
aFor this aaste coae. EPA is not regulating a specific constituent
level but instead is requiring a technology that must be used to treat
the wastes.
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2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
This section describes the industry affected by the land disposal
restrictions for K038, K039, and K040 and presents available
characterization data for these wastes. Because the Agency believes that
K036 is no longer generated by manufacturing processes, the Agency does
not have characterization data for this waste. Characterization data
also are not available for any of the P and U wastes.
Under 40 CFR 261.32, wastes identified as K038, K039, and K040 are
specifically generated in the production of Phorates and K036 is
generated in the production of Disulfoton. These wastes are listed as
fol1ows:
K036: Still bottoms from toluene reclamation distillation in the
production of Disulfoton.
K038: Wastewater from the washing and stripping of Phorate
production.
K039: Filter cake from the filtration of diethylphosphorodithioic
acid in the production of Phorate.
K040: Wastewater treatment sludge from the production of Phorate.
According to 40 CFR 261.33, the following materials are hazardous
wastes when they are discarded or are intended to be discarded; when they
are mixed with waste oil, used oil, or another material; when they are
applied to the land or are contained in products that are applied to the
land, and when they are burned as fuel:
P039 Disulfoton
P040 0,0-diethyl 0-pyrazinyl phosphorothioate
P041 Diethyl-P-nitrophenyl phosphate
P043 Diisopropyl fluorophosphate (DEP)
P044 Dimethoate
i 1'cz a
2-1
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P062 Hexaethyl tetraphosphate
P071 Methyl parathion
P085 Octamethylpyrophosphoramide
P089 Parathion
P094 Phorate
P097 Famphur
P109 Tetraethyl dithiopyrophosphate
Pill Tetraethyl pyrophosphate
U059 Cyclophosphamide
U087 0-0-diethyl-5-methly-dithiophosphate
U235 1-propanol, 2,3-dibromo-,phosphate (3:1)
These materials can be present in different forms:
• Any commercial or off-specification commercial chemical product
with any of the above generic names;
• Residues remaining in containers that held any of the
above-mentioned products; or
• The residue of contaminated soil, water, or other debris that
results when there is a cleanup of a commercial or
off-specification commercial chemical product or manufacturing
chemical intermediate having the generic name of any of the
above-listed products that had been spilled onto the land or into
the water.
The Agency has examined the source of the wastes, specific
similarities in waste composition, elemental content of the constituents
of concern in each waste, applicable and demonstrated treatment
technologies, and attainable treatment performance in order to support
the approach proposed for these listed wastes.
2.1 Industry Affected and Process Description
The four-digit Standard Industrial Classification (SIC) code
associated with the production of Phorates is 2818 (Organic Pesticide
Products). The Agency believes that only one facility currently produces
Phorates and generates K038 and K039 wastes. This facility is located in
EPA Region VII in the State of Missouri. Based on the National Survey of
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Hazardous Waste Treatment, Storage, Disposal, and Recycling Facilities of
1986 (the TSDR Survey), the Agency believes that K040 is no longer
generated. Nevertheless, as a precaution, EPA has decided to set BDAT
treatment standards for this waste as well.
The production of Phorates typically consists of the reaction of
0,0-diethyl hydrogen phosphorodithioate with formaldehyde, followed by
the addition of ethyl mercaptan (ethanethiol). The 0,0-diethyl hydrogen
phosphorodithioate is condensed with formaldehyde and ethyl mercaptan.
The reaction chemistry is as follows:
S
ii
P 2 S ^ + 4C2HjOH 2(C2H5O)^PSH + H 2 S
phosphorous etnanol 0,0-diethyl
pentasulfide hydrogen
phosphorodi thioate
S S
H M
(CgHcObPSH + H2C=0 > (C2H5O) 2PS-CH20H
0,0-aiethyl formaldehyde ditniophosphate
hydrogen
phosphorodi thioate
S S
it 11
(C2HcO)2PS-CH2OH + C2HcSH > (C2H50)2P-SCH2SC2H6 + h2o
ditniophosphate etnyl Phorate
mercaptan
Three hazardous waste streams are expected to be generated from the
production of Phorate:
1. Process wastewater (K038), which is likely to contain significant
concentrations of Phorate and lesser concentrations of other
process waste constituents including formaldehyde,
phosphorodithioic and phosphorothioic acid esters, and other main
reaction byproducts;
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2. A filter cake (K039), which is expected to contain high
concentrations of esters of phosphorodithioic acid and esters of
phosphorothioic acid; and
3. Wastewater sludges (K040) resulting from the treatment of process
waters. These sludges are expected to contain high
concentrations of Phorate because of its relative insolubility in
water. Lesser concentrations of other process constituents are
also expected to be found in the sludge.
Figure 2-1 illustrates the sources of these waste streams of concern.
P039, P040, P041. P043, P044, P062, P071, P085, P089, P094, P097,
P109. Pill. U058, U087. and U235 are generated from spills, leaks, or the
discarding of chemicals associated with the production and marketing of
the constituents in each waste.
Table 2-1 presents the number of RCRA permitted facilities that
generated the above-listed wastes and the approximate volumes produced in
1906 (CBI information is not included). The Agency estimates that about
142,797 gallons of these wastes were generated in 1986.
2.2 Waste Characterization
This section provides all waste characterization data obtained by the
Agency for K038, K039, and K040. Tables 2-2, 2-3, and 2-4 present, by
waste code, the BDAT list constituents and other parameters identified
for each waste. The K038 wastes are expected to contain Phorate.
phosphorodithioic acid esters, phosphorothioic acid esters, and
formaldehyde. As seen on Table 2-2, the concentration of Phorate, an
organophosphorous insecticide, is 50 ppm. No BDAT list constituents,
except Phorate, were detected at treatable concentrations in the
untreated K038 waste sample. The K039 wastes contain phosphorodithioic
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CBI
Figure 2-1 Phorate Production
2-5
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2315g
Table 2-1 Nunber of Facilities ai.J Volume of Organophosphorous
P and U Wastes Generated in 1986
Volune produced
Waste code No. of facilities (gallons)
P039
2
13.920
P040
2
270
P041
1
1
P043
2
2
P044
7
19.252
P062
0
0
P071
5
40.328
P085
1
1
P089
7
52.801
P094
2
14.880
P097
0
0
PI 09
0
0
Pill
0
0
U0S8
2
380
U087
1
961
U23S
1
1
Reference' USEPA 1986b
2-b
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231 Sg
Table 2-2 Available Characterization Data for &038
Untreated waste concentration
BOAT list organics
Organophosphorous insecticides
Phorate
SO. 0 ppm
Other organics
Phosphorothioic acid esters
Phosphorodithioic acid esters
Formaldehyde
Other constituents
Water4
0. S ppm
5.0 ppm
5.0 ppm
>99 X
aK038 is an aqueous saste stxise only other constituent is expected to
be aater This characteristic aas not specifically stated on the data
source, however
Reference: Environ Corporation, n.d.
2-7
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231 Sq
Table ?-3 Available Characterization Data for K039
Untreated waste concentration
Non-BDAT list organics
Phosphorodithioic acid triethyl esters 101
Phosphoroth10ic jc id triethyl esters IX
Other constituents
Water"1 89X
aK039 is a non-aqueous waste, whose only other constituent is expected
to be water This characteristic was not specifically stated on the data
source, however
Reference: Environ Corporation, n.d.
2-8
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Z31Sg
Table 2 4 Available Characterization Data for K040
Untreated waste concentration
BDAT list organics
Organophosphorous insecticides
Phorate 2.500 ppm
Other organics
Phosphorodithioic acid triethyl esters 21.000 ppn
Phosphorothioic jLid triethyl esters 2.000 ppn
formaIdenyOe 300 ppm
Other constituents
Water4 >971
dK040 is a non-aqueous waste, whose only other constituent is expected
to be water This characteristic was not specifically stated on the data
source, however
Note: It appears that this waste is no longer produced.
Reference' Environ Corporation, n.d.
2-9
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acid esters and phosphorothioic acid esters. While these are
Appendix VII constituents, they are not part of the BOAT list because
they currently cannot be analyzed at the treated concentrations.
Therefore, EPA could not enforce any proposed quantitative regulation for
these constituents. The K040 waste contains Phorate, formaldehyde,
phosphorodithioic acid triethyl ester, and phosphorothioic acid triethyl
ester. As seen on Table 2-4, the concentration of Phorate in the waste
is 2,500 ppm. No other BDAT list constituent is expected to be present
in the untreated waste.
Characterization data identified in the literature for K038, K039,
and K040 do not provide values for concentrations of BDAT list metals.
There is no reason to suspect that BDAT list metals are present in these
wastes.
2.3 Determination of Waste Treatability Group
If EPA believes that the same technologies can be used to treat
constituents present in wastes represented in different codes to similar
concentrations, the Agency may combine the codes into one separate
treatabi1ity group.
Based on review of the generation of the wastes, waste compositions,
waste management practices, and all available data characterizing these
wastes, the Agency has determined that K036, K038, K039, K040, P039,
P040, P041, P043, P044, P062, P071, P085, P089, P094, P097, P109, Pill,
U058, U087, and U235 wastes represent a single waste treatability group.
The Agency has grouped these wastes together because of similarities in
structure and elemental content of the primary constituent of concern in
2-10
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each waste (see Figure 2-2). All of the chemicals represented by these
waste codes are organophosphorous compounds.
Although the concentrations of specific constituents will vary from
one waste code to another, all of these wastes contain similar
constituents and are expected to be treatable to similar levels using the
same technologies. Consequently, EPA has examined the sources and
characteristics of these wastes, their applicable and demonstrated
treatment technologies, and their attainable treatment performance in
order to determine a single regulatory approach that would be applicable
for these wastes.
Even though constituents in all the wastes are similar to each other
and to Disulfoton (the regulated constituent in K037), the Agency is
setting concentration-based standards for some of these organophosphorous
wastes (i.e., those that have analytical methods) and technology-based
standards for the others.
The Agency is setting concentration-based standards for the wastewater
and nonwastewater forms of K038, K040, P039, P071, P089, P094, P097, and
U235; and for the wastewater forms of K036 since there are EPA-approved
analytical methods for the constituents of these wastes. The analytical
methods according to SW-846 (USEPA 1986a) are the following:
Waste Code
Constituent
Analytical
Method
K038, K040, P094
K036, P039
Phorate
Di sulfoton
Methyl parathion
Parathion
Famphur
1-propanol. 2.3-dibromo-
8270, 8140
8140
8140
8270
8270
8350
P071
P089
P097
U235
phosphate (3:1)
2-11
cl'ist)
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H H S H H H H
II II II II
H—C—C—O—P—S—C—C—S—C—C—H
II I II II
H H O H H H H
I
H—C —H
I
H—C —H
I
H
P039: DISULFOTON
S H H
.N. II I I
H —C — 0 —P—0 —C —C —H
II I I II
H —C. ^C —H O H H
N I
H—C —H
I
H —C —H
I
H
P040: O.O-DIETHYL O-PYRAZINYL PHOSPHOROTHIOATE
H H
O VC— C O H H
II // \\ II II
0=N—C C—O—P—O—C—C—H
\ ' I II
/c~cs O H H
H H I
H—C —H
I
H—C —H
I
H
P041: DIETHYL P-NITROPHENYL PHOSPHATE
H H
\ '
C
H / n
\ / H
C H
y \ /
? ° ^
F-P H H
No hn /H
\
C H
h' \
c
/ s
H H
P043: OIISOPROP YL FLUOROPHOSPH ATE
Figure 2-2 Chemical Structures tor P and U Wastes
2-12
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P089: PARATHION
P094: PHORATE
H
H—C—O
I \ S
H \ll
P—O — C
H /
H—C—O
H H
\ /
c=c
/ \ II
.C —S — N
r / 11 X "
C—cv O C
/ \
H H
O V
" /
H
H
H
H
P097: FAMPHUR
Pi 09. TETRAETHYLDITHIOPYROPHOSPHATE
Figure 2-2 (Continued)
2 - J 3
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P044: DIMETHOATE
P062: HEXAETHYl TETRAPHOSPHATE
H H
H S r. — r. O
I II / \ II
H —C—O —P—O — C ,C — N=0
II \\ //
H 0 C —C
| H H
H —C —H
I
H
P071: METHL PARATHION
H H
\ /
H H c
\ /
H
H H
\ /
~ O o
H \ N II,
N—P—O—P
/ \
H N
/ s
/CN / H
c
/ \
H H
H
\ /
C \
/ s N
H H C
/ \
H H
P085: OCTAMETHYLPYROPHOSPHORAMIDE
Figure 2-2 (Continued)
2-14
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Pill: TETRAETHYl PYROPHOSPHATE
U058: CYCLOPHOSPHAMIDE
U087: O-O-DIETHYL-5-METHYL-DITHIOPHOSPHATE
H H H O H H H
III II III
Br—C —C C —O —P—O —C —C —C —Br
III I III
H Br H O H Br H
I
H —C —H
I
H —C —Br
I
H —C —H
I
Br
U235. 1 -PROPANOL, 2,3-DI BROMO-, PHOSPHATE (3:1)
Figure 2-2 (Continued)
2-15
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Method 8270 of SW-846 has been proposed in the January 23, 1989,
update to the Third Edition of SW-846. Method 8350 will be included in
the second update to. the Third Edition of SW-846, due to be proposed in
early iyyo.
The Agency determined that the analytical methods available during
the development of the phosphorous wastes BDAT standards could not
satisfactorily measure the principal hazardous organic constituents
(organophosphorous pesticide) contained in wastes and treatment residuals
for wastes identified as K039, P040, P041, P043, P044, P062, P085. P109,
Pill, U058 and U087. Thus, the Agency is unable to promulgate
concentration-based treatment standards for these wastes and is
promulgating methods of treatment.
iq
2-16
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3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
This section identifies the treatment technologies that are
applicable to this group and determines which, if any, of the applicable
technologies can be considered demonstrated for the purpose of
establishing BOAT.
To be applicable, a technology theoretically must be usable to treat
the waste in question or to treat a waste that is similar in terms of the
parameters that affect treatment selection. (For detailed descriptions
of the technologies applicable for these wastes or for wastes judged to
be similar, see EPA's Treatment Technologies Background Document (USEPA
1988d).) To be demonstrated, the technology must be employed in
full-scale operation for the treatment of the waste in question or a
similar waste. Technologies that are available only at research
facilities or at pilot- and bench-scale operations are not typically
considered in identifying demonstrated technologies.
3.1 Applicable Treatment Technologies
Since the organophosphorous wastes contain organics, the technologies
applicable to the untreated listed wastes should include those that
destroy or reduce the total amount of various organic compounds in the
waste.
For nonwastewaters, the Agency has identified incineration as an
applicable treatment technology to treat the organophosphorous wastes.
Technologies such as fuel substitution and solvent extraction also may be
applicable to the treatment of the above-mentioned wastes as generated.
3-1
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In addition, the Agency believes that wet air oxidation, incineration,
biological treatment, and carbon adsorption are applicable to treat the
wastewater forms of the organophosphorous wastes.
Incineration is a destruction technology in which energy, in the form
of heat, is transferred to the waste to destabilize chemical bonds and
eventually destroy hazardous constituents by converting them to carbon
dioxide, water, and other oxidized waste constituents. In general, the
two residuals generated by incineration processes are ash and combustion
gas scrubber water.
Biological treatment is a technology that uses living microorganisms
to decompose organic constituents. Biological treatment can occur either
in the presence of oxygen, where it is known as aerobic treatment, or in
the absence of oxygen, where it is referred to as anaerobic treatment.
The organic constituents are broken down into water, carbon dioxide, and
other organic constituents by the microorganisms.
Carbon adsorption is a separation technology used to remove and/or
recover dissolved organics and certain inorganics from aqueous streams by
adsorbing the dissolved constituents on the surface of the activated
carbon particles. Powdered or granular activated carbon particles are
used as the adsorbing medium in this technology.
3.2 Demonstrated Treatment Technologies
Of the above-mentioned technologies applicable for BDAT list organic
constituents, the Agency believes that incineration is demonstrated to
treat the nonwastewater and the wastewater forms of the organophosphorous
3-2
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wastes, since this technology is currently being used by one facility to
treat some of these wastes. Incineration is also being used to treat
similar wastes (e.g.. K037, wastewater treatment sludge from the
production of Disulfoton).
The Agency considers carbon adsorption to be a demonstrated
technology for the wastewater forms of these wastes, since carbon
adsorption is being used to treat constituents with characteristics
similar to the organophosphorous wastes. EPA believes that the organic
constituents in these wastes can easily be adsorbed on carbon because of
the chemical and physical properties of the compounds (such as their
molecular weight, elemental composition, and structural forms).
The Agency has identified one facility that uses biological treatment
on wastewaters containing Parathion. Therefore, EPA considers biological
treatment to be a demonstrated technology for the wastewater forms of the
organophosphorous wastes. Biological treatment data were provided during
the comment period for the Land Disposal Restrictions for Second Third
Scheduled wastes; Proposed Rule (54 FR 1056, January 19, 1989). This
technology has been used to treat Parathion which the Agency believes is
similar to these wastes and indeed is included in this treatability group.
3-3
-------
4. PERFORMANCE DATA BASE
This section presents the data available on the performance of
demonstrated technologies in treating the listed wastes. These data are
used elsewhere in this document for determining which technologies
represent BDAT (Section 5), for selecting constituents to be regulated
(Section 6), and for developing treatment standards (Section 7).
Eligible data may include data developed at bench- or pilot-scale
facilities or obtained through other applications at less than full-scale
operation, as long as the technology is demonstrated in full-scale
operation for a similar waste or wastes.
Performance data, to the extent that they are available to EPA,
include the untreated and treated waste concentrations for a given
constituent,, the values of operating parameters that were measured at the
time the waste was being treated, the values of relevant design
parameters for the treatment technology, and data on waste
characteristics that affect performance of the treatment technology.
Where data are not available on the treatment of the specific wastes
of concern, the Agency may elect to transfer data on the treatment of a
similar waste or wastes, using a demonstrated technology. To transfer
data from another waste category, EPA must find that the wastes covered
by this background document are no more difficult to treat (based on the
waste characteristics that affect performance of the demonstrated
treatment technology) than the treated wastes from which performance data
are being transferred.
d 1 2
4-1
-------
The Agency has no data to characterize treatment for the
nonwastewater forms of the listed wastes; however, the Agency has a data
base for incineration of a similar waste (K037), which, according to
40 CFR 261.32, is listed as wastewater treatment sludge from the
production of Disulfoton. Performance concentration levels for K037
wastewaters and nonwastewaters have already been promulgated
(53 FR 31157, August 17, 1988). These standards were based on the
performance of incineration of K037 nonwastewaters in a rotary kiln and
the concentration of hazardous constituents found in the ash and scrubber
water residuals.
The Agency's decision to transfer performance data standards for the
nonwastewater forms of the organophosphorous wastes from the incineration
of K037 wastes is based on the similarities in structure and elemental
composition of all of the organophosphorous pesticides to each other and
to Disulfoton, the principal hazardous constituent of concern in K037
wastes. As an example, the only difference in chemical structure between
Phorate and Disulfoton is the additional methylene (-CH^-) group in
Disulfoton (see Figures 4-1 and 4-2).
Tables 4-1 through 4-6 of the Best Demonstrated Available Technology
(BDAT) Background Document for K037 (USEPA 1988a) present the six data
sets of total waste concentration analyses for K037 waste samples and the
design and operating data for the incineration treatment system. As
shown by the operating data taken during sample collection, all six data
4-2
-------
H H S H
H H
I I II I
I I
z
I
-o
I
-o
I
0
1
-•o
I
in
I
-o
I
(0
— C —C
I 1
- I
-o
- X
- I
I 1
H H
H —C —H
I
H —C —H
H
FIGURE 4-1 PHORATE CHEMICAL STRUCTURE
H
|
H
|
S
n
H
1
H H H
i i i
C
|
1
—c
1
1
0
1
-u =
1
in
1
—c
1
I
- o -
1
Iff
1
-a -
1
-o -
1
H
1
H
0
\
1
H
1 1 1
H H H
z
i
- o-
1
X
X
1
- o-
1
X
H
FIGURE 4-2 DISULFOTON CHEMICAL STRUCTURE
4-3
-------
sets reflect treatment by a wel1-operated system. Furthermore, all the
data sets show that the organic BDAT list constituents detected in the
untreated wastes are.treated to nondetectable levels in the treatment
residuals.
The proposed treatment standards for the wastewater forms of these
organophosphorous pesticides were based on the concentrations of
Disulfoton as measured in grab samples of scrubber water from the
incineration of K037 nonwastewaters. EPA has decided to change these
standards in the final rule based on additional performance data for a
biological wastewater treatment system submitted during the comment
period. These data were from the treatment of industrial wastewaters
containing low concentrations of Parathion. Table 4-1 presents this data
set. Although these data (based on analysis of grab samples for influent
wastes and composite samples for effluent) were not generated
specifically for this rulemaking and do not result from the direct
treatment of a RCRA waste identified as P089 (Parathion), the Agency
believes that these wastewaters have concentrations of Parathion that are
expected to be similar to the constituent concentrations in those
wastewaters identified specifically as K036, K038, K040, P039, P071,
P089, P094, P097 or U235. Available data for K038 wasatewaters show
levels of Phorate in the same range as Parathion levels in wastewaters
included in the biological treatment data received. The Agency has also
determined that these data are valid and represent the level of
performance that appears to be achievable for this type of biological
wastewater treatment system.
4-4
-------
EPA believes these data to be a preferable measure of treatment
performance because where the Agency has performance data (that conform
with BDAT methodology) on wastewater treatment processes and data on
incineration (constituent concentrations in scrubber water), the Agency
prefers to establish treatment standards based on the wastewater
treatment processes. This does not preclude the Agency from establishing
treatment standards for other wastes based on constituent concentrations
in incinerator scrubber waters.
4-5
-------
Table 4-1 Biological Treatment for Parathion
Untreated
Treated
Untreated
Treated
Sample
waste
waste
Sample
waste
waste
number
(DDm)
(DDm)
number
(DDm)
(DDm)
1
18
<0.01
47
26
<0.01
2
62
<0.01
48
15
<0.01
3
20
<0.01
49
16
<0.01
4
36
<0.01
50
29
<0.01
5
35
<0.01
51
36
<0.01
6
10
<0.01
52
41
<0.01
7
20
<0.01
53
18
<0.01
8
14
<0.01
54
5
<0.01
9
22
<0.01
55
6
<0.01
10
20
<0.01
56
59
<0.01
11
25
<0.01
57
31
<0.01
12
22
<0.01
58
22
<0.01
13
12
<0.01
59
24
<0.01
14
18
<0.01
60
28
<0.01
15
17
<0.01
61
30
<0.01
16
23
<0.01
62
15
<0.01
17
34
<0.01
63
15
<0.01
18
20
<0.01
64
30
<0.01
19
42
<0.01
65
25
<0.01
20
26
<0.01
66
12
<0.01
21
22
<0.01
67
17
<0.01
22
70
<0.01
68
23
<0.01
23
33
<0.01
69
15
<0.01
24
96
<0.01
70
18
<0.01
25
23
<0.01
71
21
<0.01
26
21
<0.01
72
26
<0.01
27
30
<0.01
73
17
<0.01
28
28
<0.01
74
12
<0.01
29
17
<0.01
75
20
<0.01
30
26
<0.01
76
9
<0.01
31
23
<0.01
77
18
<0.01
32
12
<0.01
78
15
<0.01
33
20
<0.01
79
11
<0.01
34
34
<0.01
80
17
<0.01
35
25
<0.01
81
18
<0.01
36
19
<0.01
82
9
<0.01
37
15
<0.01
83
20
<0.01
38
20
<0.01
84
18
<0.01
39
17
<0.01
85
17
<0.01
40
14
<0.01
86
21
<0.01
41
18
<0.01
87
8
<0.01
42
13
<0.01
88
21
<0.01
43
14
<0.01
89
15
<0.01
44
22
<0.01
90
18
<0.01
45
23
<0.01
91
9
<0.01
46
15
<0.01
92
11
<0.01
-------
2 7 08g
Table 4-1 (continued)
Untreated
Treated
Untreated
Treated
Sample
waste
waste
Sample
waste
waste
number
(DDm)
(DDm)
number
(DDm)
(DDm)
93
11
<0.01
139
5
<0.01
94
16
<0.01
140
17
<0.01
95
14
<0.01
141
8
<0.01
96
16
<0.01
142
5
<0.01
97
22
<0.01
143
5
<0.01
98
10
<0.01
144
13
<0.01
99
22
<0.01
145
11
<0.01
100
15
<0.01
146
53
<0.01
101
14
<0.01
147
14
<0.01
102
12
<0.01
148
13
<0.01
103
21
<0.01
149
7
<0.01
104
14
<0.01
150
5
<0.01
105
14
<0.01
151
5
<0.01
106
9
<0.01
152
4
<0.01
107
16
<0.01
153
6
<0.01
108
9
<0.01
154
2
<0.01
109
14
<0.01
155
3
<0.01
110
20
<0.01
156
4
<0.01
111
24
<0.01
157
3
<0.01
112
5
<0.01
158
5
<0.01
113
4
<0.01
159
7
<0.01
114
7
<0.01
160
3
<0.01
115
8
<0.01
161
5
<0.01
116
10
<0.01
162
2
<0.01
117
13
<0.01
163
2
<0.01
118
6
<0.01
164
6
<0.01
119
13
<0.01
165
16
<0.01
120
9
<0.01
166
19
<0.01
121
6
<0.01
167
38
<0.01
122
5
<0.01
168
29
<0.01
123
7
<0.01
169
16
<0.01
124
7
<0.01
170
10
<0.01
125
4
<0.01
171
13
<0.01
126
5
<0.01
172
4
<0.01
127
5
<0.01
173
3
<0.01
128
9
<0.01
174
57
<0.01
129
7
<0.01
175
10
<0.01
130
6
<0.01
176
11
<0.01
131
9
<0.01
177
15
<0.01
132
7
<0.01
178
15
<0.01
133
11
<0.01
179
7
<0.01
134
3
<0.01
180
10
<0.01
135
3
<0.01
181
5
<0.01
136
1
<0.01
182
6
<0.01
137
6
<0.01
183
7
<0.01
138
21
<0.01
184
8
<0.01
-------
2 7 08g
Table 4-1 (continued)
Untreated
Treated
Untreated
Treated
Sample
waste
waste
Sample
waste
waste
number
(DDm)
(DDm)
number
(DDm)
(DDm)
185
7
<0.01
231
6
0.01
186
5
<0.01
232
6
<0.01
187
5
<0.01
233
2
<0.01
188
10
<0.01
234
3
<0.01
189
7
<0.01
235
4
<0.01
190
9
<0.01
236
6
<0.01
191
4
<0.01
237
6
<0.01
192
13
<0.01
238
2
<0.01
193
7
<0.01
239
7
<0.01
194
9
<0.01
240
8
<0.01
195
8
<0.01
241
3
<0.01
196
7
<0.01
242
4
<0.01
197
6
<0.01
243
2
<0.01
198
9
<0.01
244
2
<0.01
199
5
<0.01
245
4
<0.01
ZOO
8
<0.01
246
14
<0.01
201
5
<0.01
247
6
<0.01
202
9
<0.01
248
2
<0.01
203
4
<0.01
249
6
<0.01
204
5
<0.01
250
5
<0.01
205
5
<0.01
251
7
<0.01
206
6
<0.01
252
22
<0.01
207
2
<0.01
253
4
<0.01
208
5
<0.01
254
2
<0.01
209
7
<0.01
255
9
<0.01
210
4
<0.01
256
2
<0.01
211
7
<0.01
257
2
<0.01
212
3
<0.01
258
2
<0.01
213
2
<0.01
259
6
<0.01
214
6
<0.01
260
3
<0.01
215
3
<0.01
261
7
<0.01
216
3
<0.01
262
12
<0.01
217
2
<0.01
263
40
<0.01
218
2
<0.01
264
146
<0.01
219
3
<0.01
265
59
<0.01
220
3
<0.01
266
13
<0.01
221
2
<0.01
267
13
<0.01
222
2
<0.01
268
25
<0.01
223
2
<0.01
269
14
<0.01
224
4
<0.01
270
15
<0.01
225
4
<0.01
271
85
<0.01
226
7
<0.01
272
122
<0.01
227
2
<0.01
273
32
<0.01
228
5
<0.01
274
26
<0.01
229
8
<0.01
275
21
<0.01
230
2
<0.01
276
13
<0.01
-------
2 7 08g
Table 4-1 (continued)
Untreated
Treated
Untreated
Treated
Sample
waste
waste
Sample
waste
waste
number
(DDfJl)
(DDm)
number
(DDm)
(DDm)
111
15
<0.01
323
7
<0.01
278
17
<0.01
324
6
<0.01
279
13
<0.01
325
14
<0.01
280
23
<0.01
326
13
<0.01
281
16
<0.01
327
11
<0.01
282
15
<0.01
328
12
<0.01
283
27
<0.01
329
11
<0.01
284
32
<0.01
330
7
<0.01
285
24
<0.01
331
7
<0.01
286
21
<0.01
332
11
<0.01
287
22
<0.01
333
8
<0.01
288
25
<0.01
334
8
<0.01
289
18
<0.01
335
6
<0.01
290
6
<0.01
336
6
<0.01
291
13
<0.01
337
12
<0.01
292
7
<0.01
338
8
<0.01
293
21
<0.01
339
11
<0.01
294
3
<0.01
340
6
<0.01
295
11
<0.01
341
15
<0.01
296
28
<0.01
342
9
<0.01
297
16
<0.01
343
5
<0.01
298
7
<0.01
344
8
<0.01
299
40
<0.01
345
16
<0.01
300
20
<0.01
346
17
<0.01
301
11
<0.01
347
11
<0.01
302
18
<0.01
348
13
<0.01
303
12
<0.01
349
7
<0.01
304
8
<0.01
350
15
<0.01
305
23
<0.01
351
9
<0.01
306
11
<0.01
352
9
<0.01
307
18
<0.01
353
9
<0.01
308
26
<0.01
354
11
<0.01
309
10
<0.01
355
14
<0.01
310
11
<0.01
356
5
<0.01
311
8
<0.01
357
4
<0.01
312
5
<0.01
358
8
<0.01
313
11
<0.01
359
8
<0.01
314
12
<0.01
360
20
<0.01
315
20
<0.01
361
5
<0.01
316
6
<0.01
362
6
0.01
317
9
<0.01
363
14
<0.01
318
9
<0.01
364
9
<0.01
319
11
<0.01
365
13
<0.01
320
9
<0.01
366
7
<0.01
321
8
<0.01
367
10
<0.01
322
3
<0.01
368
9
<0.01
-------
2708g
Table 4-1 (continued)
Untreated
Treated
Untreated
T reated
Sample
waste
waste
Sample
waste
waste
number
(DDm)
(DDm)
number
(DDm)
(DDm)
369
9
<0.01
415
7
<0.01
370
9
<0.01
416
5
<0.01
371
7
<0.01
417
14
<0.01
372
6
<0.01
418
6
<0.01
373
5
<0.01
419
6
<0.01
374
9
<0.01
420
4
<0.01
375
7
<0.01
421
3
<0.01
376
11
<0.01
422
6
<0.01
377
17
<0.01
423
6
<0.01
378
13
<0.01
424
12
<0.01
379
22
<0.01
425
3
<0.01
380
7
<0.01
426
2
<0.01
381
14
<0.01
427
2
<0.01
382
7
<0.01
428
2
<0.01
383
6
<0.01
429
2
<0.01
384
6
<0.01
430
2
<0.01
385
5
<0.01
431
3
<0.01
386
6
<0.01
432
3
<0.01
387
6
<0.01
433
3
<0.01
388
13
<0.01
434
6
<0.01
389
10
<0.01
435
3
<0.01
390
5
<0.01
436
5
<0.01
391
17
<0.01
437
6
<0.01
392
11
<0.01
438
8
<0.01
393
20
<0.01
439
9
<0.01
394
20
<0.01
440
9
<0.01
395
9
<0.01
441
4
<0.01
396
9
<0.01
442
7
<0.01
397
9
<0.01
443
10
<0.01
398
11
<0.01
444
6
<0.01
399
9
<0.01
445
5
<0.01
400
7
<0.01
446
5
<0.01
401
5
<0.01
447
5
<0.01
402
9
<0.01
448
3
<0.01
403
5
<0.01
449
3
<0.01
404
8
<0.01
450
8
<0.01
405
9
<0.01
451
5
<0.01
406
4
<0.01
452
8
<0.01
407
9
<0.01
453
4
<0.01
408
6
0.01
454
7
<0.01
409
8
<0.01
455
2
<0.01
410
5
<0.01
456
5
<0.01
411
7
<0.01
457
3
<0.01
412
10
<0.01
458
6
<0.01
413
3
<0.01
459
4
<0.01
414
6
<0.01
460
4
<0.01
-------
2708g
Table 4-1 (continued)
Untreated
Treated
Untreated
Treated
Sample
waste
waste
Sample
waste
waste
number
(DDm)
(DDm)
number
(DDm)
(DDm)
461
5
<0.01
507
3
<0.01
462
9
<0.01
508
4
<0.01
463
5
<0.01
509
4
<0.01
464
5
<0.01
510
5
<0.01
465
7
<0.01
511
5
<0.01
466
8
<0.01
512
4
<0.01
467
3
<0.01
513
4
<0.01
468
3
<0.01
514
4
<0.01
469
2
<0.01
515
4
<0.01
470
4
<0.01
516
4
<0.01
471
3
<0.01
517
5
<0.01
472
4
<0.01
518
15
<0.01
473
5
<0.01
519
10
<0.01
474
4
<0.01
520
6
<0.01
475
4
<0.01
521
3
<0.01
476
2
<0.01
522
10
<0.01
474
2
<0.01
523
17
<0.01
475
2
<0.01
524
21
<0.01
479
1
<0.01
525
37
<0.01
480
4
<0.01
526
72
<0.01
481
2
<0.01
527
31
<0.01
482
2
<0.01
528
20
<0.01
483
9
<0.01
529
30
<0.01
484
4
<0.01
530
22
<0.01
485
6
<0.01
531
35
<0.01
486
7
<0.01
532
16
<0.01
487
6
<0.01
533
12
<0.01
488
9
<0.01
534
18
<0.01
489
9
<0.01
535
32
<0.01
490
5
<0.01
536
33
<0.01
491
3
<0.01
537
37
<0.01
492
5
<0.01
538
13
<0.01
493
6
<0.01
539
5
<0.01
494
3
<0.01
540
6
<0.01
495
3
<0.01
541
5
<0.01
496
4
<0.01
542
13
<0.01
497
1
<0.01
543
7
<0.01
498
1
<0.01
544
4
<0.01
499
6
<0.01
545
12
<0.01
500
3
<0.01
546
8
<0.01
501
2
<0.01
547
21
<0.01
502
6
<0.01
548
17
<0.01
503
6
<0.01
549
13
<0.01
504
5
<0.01
550
8
<0.01
505
8
<0.01
551
13
<0.01
506
4
<0.01
552
6
<0.01
-------
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
Table 4-1 (continued)
Untreated
Treated
Untreated
Treated
waste
waste
Sample
waste
waste
(DDm)
(DDfD)
number
(DDm)
(DDm)
9
<0.01
599
11
<0.01
10
<0.01
600
5
<0.01
17
<0.01
601
4
<0.01
12
<0.01
602
7
<0.01
12
<0.01
603
5
<0.01
11
<0.01
604
12
<0.01
3
<0.01
605
9
0.01
7
<0.01
606
2.4
0.002
7
<0.01
607
2.6
0.001
7
<0.01
608
0.8
0.002
13
<0.01
609
1.5
0.002
5
<0.01
610
1.0
0.004
10
<0.01
611
1.9
0.002
15
<0.01
612
1.3
0.001
11
<0.01
613
4.1
0.003
14
<0.01
614
13.6
0.003
7
<0.01
615
5.0
0.005
14
<0.01
616
6.5
0.014
10
<0.01
617
7.7
0.002
12
<0.01
618
4.9
0.003
21
<0.01
619
5.4
0.004
5
<0.01
620
4.1
0.002
5
<0.01
621
4.9
0.003
10
<0.01
622
10.8
0.002
9
<0.01
623
9.0
0.004
14
<0.01
624
7.7
0.004
12
<0.01
625
5.6
0.004
9
<0.01
626
7.5
0.015
26
<0.01
627
8.5
0.013
37
<0.01
628
10.4
0.008
11
<0.01
629
15.2
0.004
11
<0.01
630
16.2
0.003
8
<0.01
631
9.7
0.002
6
<0.01
632
3.9
0.004
9
<0.01
633
4.7
0.003
20
<0.01
634
6.1
0.018
7
<0.01
635
11.0
0.002
17
<0.01
636
7.7
0.002
9
<0.01
637
8.6
0.002
10
<0.01
638
10.7
0.006
5
<0.01
639
3.0
0.016
7
<0.01
640
6.8
0.009
6
<0.01
641
6.3
0.008
2
<0.01
642
17.1
0.010
19
<0.01
643
9.1
0.006
21
<0.01
644
5.3
0.008
-------
2 7 08g
Table 4-1 (continued)
Untreated
T reated
Untreated
Treated
Samp!e
waste
waste
Sample
waste
waste
number
(DDm)
(dditi)
number
(DDm)
(DDm)
645
4.3
0.002
669
15.3
0.006
646
8.5
0.006
670
20.2
0.003
647
8.8
0.008
671
11.5
0.005
648
5.6
0.005
672
37.4
0.010
649
5.8
0.004
673
10.0
0.007
650
6.9
0.001
674
10.5
0.002
651
14.8
0.007
675
15.3
0.005
652
9.2
0.005
676
6.4
0.002
653
8.4
0.003
677
4.5
0.001
654
4.8
0.002
678
15.4
0.002
655
6.8
0.004
679
13.6
0.006
656
19.0
0.001
680
10.1
0.003
657
5.9
0.002
681
9.3
0.002
658
5.7
0.005
682
2.1
0.002
659
7.0
0.003
683
1.6
0.003
660
2.7
0.003
684
1.4
0.003
661
9.9
0.002
685
1.9
0.004
662
6.6
0.004
686
2.2
0.004
663
10.0
0.004
687
4.8
0.004
664
12.8
0.003
688
7.5
0.003
665
12.7
0.003
689
3.3
<0.001
666
15.3
0.004
690
2.3
0.001
667
9.9
0.006
691
2.6
<0.001
668
5.6
0.002
692
1.5
0.001
-------
5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
This section presents the Agency's rationale for the determination of
best demonstrated available technology (BDAT) for the organophosphorous
nonwastewaters and wastewaters. BDAT must be specifically defined for
all streams associated with the management of the listed waste or wastes;
this pertains to the original waste as well as to any residual waste
streams created by the treatment process.
To determine BDAT, the Agency examines all available performance data
on technologies that are identified as demonstrated to determine (using
statistical techniques) whether one or more of the technologies performs
significantly better than the others. In addition, all performance data
used for determination of best technology are first adjusted for
accuracy, as discussed in EPA's publication Methodology for Developing
BDAT Treatment Standards (USEPA 1988c). (An accuracy adjustment accounts
for the ability of an analytical technique to recover a particular
constituent from the waste in a particular test. The recovery of a
constituent is usually determined by spiking a raw waste sample with a
known amount of the target constituent and then comparing the amount
recovered with results from unspiked samples of the waste.)
The technology that performs best on a particular waste or waste
treatability group is then evaluated to determine whether it is
"available." To be available the technology must (1) be commercially
available to any generator and (2) provide "substantial" treatment of the
waste, as determined through evaluation of accuracy-adjusted data. In
Wiz c
5-1
-------
determining whether treatment is substantial, EPA may consider data on
the performance of a waste similar to the waste in question provided that
the similar waste is at least as difficult to treat. If the best
technology is found to be not available, then the next best technology is
evaluated, and so on.
The Agency is promulgating BOAT treatment standards based on hazardous
constituent concentrations for the wastewater and nonwastewater forms of
K038, K040, P039, P071, P089, P094, P097, and U235 and the wastewater
forms of K036. As previously discussed, the Agency currently is not able
to adequately analyze the constituents of the K039, P040, P041, P043,
P044, P062, P085, P109, Pill, U058, and U087 treatment residues; thus, it
is promulgating standards that require a specific treatment technology
for the wastewater and nonwastewater forms of this waste, rather than
constituent concentration standards.
5.1 Nonwastewaters
Consistent with EPA's methodology for determining BDAT, the Agency
evaluated the incineration performance data for the similar waste (K037)
to determine whether this technology would provide statistically
significant treatment for BDAT list organic constituents in the wastes in
this treatability group. Based on the evaluation of the design and
operating parameters of the treatment system, the analytical testing, and
the quality of the data, EPA determined that incineration does provide
statistically significant treatment. This determination is based on the
fact that the BDAT list organic constituents were reduced to nondetectable
5-2
-------
levels in the treatment residuals. Incineration is also a widely
available commercial technology. Consequently, the Agency concluded that
incineration alone is BDAT for the nonwastewater forms of these wastes.
Performance data for a similar waste (K037) indicated that organic
residuals in the ash and the scrubber water were below detection limits.
The Phorate detection limit was 0.0165 mg/kg for the treated waste and
0.5 mg/1 for the scrubber water (USEPA 1988a). The Agency concluded that
there is no need for additional treatment of nonwastewater or wastewater
residuals resulting from incineration of K037 and that incineration alone
is BDAT for all nonwastewaters of this waste. Since the wastes in this
treatability group are similar to K037 (Disulfoton), the Agency likewise
concluded that incineration is demonstrated, and thus it was selected for
determination of BDAT treatment standards for all nonwastewater forms of
these wastes. As with K037 treatment residuals, the Agency concluded
that there is no need for additional treatment of nonwastewater and
wastewater incineration residuals of these treated wastes.
5.2 Wastewaters
For those wastewaters for which the principal hazardous constituent
can be measured, EPA proposed performance standards based on
concentrations of Disulfoton as measured in grab samples of scrubber
water from the incineration of K037 nonwastewaters. EPA has decided to
change these standards in the final rule based on additional performance
data (concentrations of Parathion as measured in composite samples) for a
biological wastewater treatment system submitted by Monsanto during the
comment period. These data (see Table 4-1) indicate that wastewater
5-3
-------
streams containing Parathion managed by biological treatment were treated
to levels at or nearly at the detection limit levels found for
incinerator scrubber water. The Agency has also determined that these
data are valid and represent the level of performance that appears to be
achievable for this type of biological wastewater treatment system.
EPA believes that these data for biological treatment of Parathion
can be validly transferred to the wastewater forms of the other
organophosphorous pesticide waste codes. This is due to the structural
similarity between Parathion and the other organophosphorous wastes.
Thus, the Agency is promulgating revised concentration-based standards
for the wastewater forms of K036, K038, K040, P039, P071, P087, P094,
P097, and U235 based on analysis of composite samples from wastewater
treatment.
The Agency has determined that currently there are no analytical
methods that allow the measurement of the principal hazardous constituent
(organophosphorous pesticide) contained in wastes and treatment residuals
for wastes identified as K039, P040, P041, P043, P044, P062, P085. P109.
Pill, U058, and U087. Thus, the Agency is unable to promulgate
concentration-based treatment standards for these wastes and is
promulgating methods of treatment. Although EPA prefers a
concentration-based standard (both because of the greater flexibility in
choice of technology used to achieve the standard and the greater control
afforded to ensure efficient design and operation of the chosen
technology), in the absence of analytical methods (that would measure and
assure compliance), the Agency believes that establishing a method of
5-4
ni~z
-------
treatment is the only logical alternative for BDAT. In general, the
majority of commenters on this issue supported this approach. Further,
EPA believes that this is consistent with the promulgated BDAT
methodology and with RCRA section 3004(m), which authorizes the Agency to
establish either levels or methods of treatment. Therefore, today's rule
promulgates methods of treatment for these wastes.
For the wastewater forms of these organophosphorous wastes, the
Agency proposed carbon adsorption as the BDAT treatment method in
54 FR 1086 (January 11. 1989). EPA believes that the primary
constituents of these wastes can easily be adsorbed on carbon because of
the chemical and physical properties of the compounds (such as their
molecular weight, elemental composition, and structural form). Spent
carbon and any other nonwastewater residuals generated upstream from a
carbon adsorption unit must meet the nonwastewater standards applicable
to these wastes prior to land disposal.
Several commenters suggested that there are cases in which it may be
preferable to incinerate the wastewater rather than to have the waste
adsorbed by carbon. Two examples of this situation occur when: (1) the
waste appears as a result of the "mixture-rule" with other waste codes
for which the BDAT treatment method requires incineration, and (2) the
waste is generated so that it contains a relatively high level of TOC but
just under the 1 percent TOC cutoff and maintains its classification (for
purposes of BDAT) as a wastewater. In either case, the Agency agrees
with the commenter that incineration would then be the preferred or
required (as in the case of the first example) method of treatment. In
5-5
-------
fact, the Agency did consider incineration as an alternative destructive
technology to carbon adsorption. However, it seemed impractical to
require all wastewater streams to be incinerated. (Some data indicated
that the majority of hazardous wastewaters contain significantly less
than 1 percent TOC.)
Thus, the Agency is promulgating "Incineration or Carbon Adsorption
as a Method of Treatment" as BDAT for the wastewater forms of wastes
identified as K039, P040, P041, P043, P044, P062, P085, P109, Pill, U058,
and U087.
5-6
-------
6. SELECTION OF REGULATED CONSTITUENTS
This section presents the rationale for the selection of regulated
constituents for the treatment of K036, K038, K039, and K040 wastes.
Constituents selected for regulation must satisfy the following
cri teri a:
1. They must be on the BDAT list of regulated constituents.
(Presence on the BDAT list implies the existence of approved
techniques for analyzing the constituent in treated waste
matrices.)
2. They must be present in, or be suspected of being present in, the
untreated waste. For example, in some cases, analytical
difficulties (such as masking) may prevent a constituent from
being identified in the untreated waste, but its identification in
a treatment residual may lead the Agency to conclude that it is
present in the untreated waste.
3. Where performance data are transferred, the selected constituents
must be easier to treat than the waste constituent(s) from which
performance data are transferred. Factors for assessing ease of
treatment will vary according to the technology of concern. For
instance, for incineration the factors include bond dissociation
energy, thermal conductivity, and boiling point.
From the group of constituents that are eligible to be regulated. EPA
may select a subset of constituents as representative of the broader
group. For example, out of a group of constituents that react similarly
to treatment, the Agency might name only those that are the most
difficult to treat as regulated constituents for the purpose of setting a
standard.
6.1 Identification of BDAT List Constituents
As discussed in Sections 2 and 4, the Agency has characterization
data for K038, K039, and K040, as well as performance data from treatment
of a similar waste (K037) and from treatment of Parathion. These data.
6-1
-------
along with information on the waste-generating process, have been used to
determine which BDAT list constituents may be present in the waste and
thus which are potential candidates for regulation in K038, K039, and
K040 wastes. Constituents that were not expected to be in the untreated
waste were not considered for regulation. The other U and P wastes in
this treatability group do not require a constituent selection since
there is only one constituent that characterizes each one of them.
6.2 Constituent Selection
Since there are no treatment performance data from incineration of
K038, K039, and K040, the Agency has transferred performance data from
the treatment of K037 at plant A (USEPA 1988a) to the above-listed
wastes. This transfer of treatment data is supported both by the
determination that all of these wastes are generated by the
organophosphorous industry and by the Agency's belief that constituents
present in K038, K039 and K040 are similar to those in K037, and thus are
amenable to the same treatment technology.
The determination of adequate control for the constituents was based
on an evaluation of the characteristics of the constituents (i.e., the
boiling point and the bond dissociation energy) that would affect the
performance of incineration. In general, a constituent with a low
boiling point and low dissociation energy would be easier to treat by
incineration than would constituents with higher boiling points and
higher dissociation energies.
il'i-j q
6-2
-------
The constituent having the same or the closest higher boiling point
and bond dissociation energy, for which the Agency had treatment
performance data from K037 at plant A, was selected for transfer of data.
Phorate is the only BDAT list constituent expected to be present in
K038 and K040 wastes. It also has characteristics similar to Disulfoton,
the constituent treated and regulated in the similar waste (K037).
Table 6-1 presents the constituent characteristics that affect the
performance of incineration for the K037 regulated constituent
(Disulfoton), from which the standards are being transferred, and for the
K038 and K040 constituent to be regulated (Phorate). As can be seen in
this table, the boiling point and the bond dissociation energy values of
Phorate are lower than the values for Disulfoton. This condition
indicates that Phorate should be easier to incinerate than Disulfoton.
The EPA-approved analytical methods for measurement of Phorate in the
wastes and treated residuals for K038 and K040 are listed in the SW-846
publication as methods 8140 and 8141 (USEPA 1986a).
Based on the discussion of waste characteristics affecting treatment
performance of incineration in the Treatment Technologies Background
Document, the Agency expects that Phorate can be treated to concentration
levels as low as or lower than Disulfoton.
Because the Agency has determined that currently, there are no
analytical methods that Si low the measurement of the principal hazardous
constituents contained in K039 wastes and treatment residuals, numerical
standards cannot be established. However, since the constituents in
6-3
-------
Z31 Sg
Table 6-1 Waste Characteristics Affecting Perfornance of Incineration
Bond dissociation
Constituent Waste code Boiling point energy
(Kca1/mol)
Oisulfoton *.03/ 132" - 133*C( 1.Sam Hg)a 2860
Phorate H038. H040 125" - 127*C(2 Omn Hg)a 2755
a Merck, and Co.. 1983.
Table 6-2 Regulated Constituents for K.038 and K040
Regu lated
Waste code constituent
K038
*040
Phorate
Phorate
-------
these wastes are structurally similar to Phorate and are generated during
its production, the Agency has determined that incineration is BDAT for
this waste, as noted.in Section 5. Because the K039 constituents cannot
be analyzed at the treated levels, however, the Agency is requiring the
use of the incineration technology as BDAT and not setting a performance
concentration level standard for any particular constituents.
Table 6-2 shows the BDAT list constituents that were selected by the
Agency to regulate K038 and K040 wastes.
6-5
-------
7. DEVELOPMENT OF BDAT TREATMENT STANDARDS
The Agency bases treatment standards for regulated constituents on
the performance of wel1-designed and wel1-operated BDAT treatment
systems. These standards must account for analytical limitations in
available performance data and must be adjusted for variabilities related
to treatment, sampling, and analytical techniques and procedures.
BDAT standards are determined for each constituent by multiplying the
arithmetic mean of accuracy-adjusted constituent concentrations detected
in treated waste by a "variability factor" specific to each constituent.
Accuracy adjustment of performance data was discussed in Section 5 in
relation to defining "substantial treatment." Variability factors
correct for normal variations in the performance of a particular
technology over time. They are designed to reflect the 99th percentile
level of performance that the technology achieves in commercial
operation. (For more information on the principles of calculating
variability factors, see EPA's publication, Methodology for Developing
BDAT Treatment Standards. For details on the calculation of variability
factors for the organophosphorous wastes, see Appendix A of the Best
Demonstrated Available Technology (BDAT) Background Document for K037
(USEPA 1988a).)
Where EPA has identified BDAT for a particular waste but because of
data limitations or some other compelling reason cannot define specific
concentration treatment standards for that waste, the Agency can require
the use of that treatment process as a technology standard. Similarly.
IV'w
7-1
-------
where EPA believes that the waste can be totally recycled or reused as' a
raw material, the Agency may specify a "no land disposal" standard, which
effectively amounts to setting the performance standard at zero for all
waste constituents.
In the case of K036, K038, K040, P039, P071, P089, P094, P097, and
U235, the Agency is promulgating concentration-based treatment standards
for the regulated constituent as shown in Tables 7-1 and 7-2. The
nonwastewater treatment standard of 0.10 ppm is directly transferred from
the performance achieved by rotary kiln incineration of K037 and the
concentration of organophosphorous pesticide measured in the ash residual.
Standards applicable to the wastewaters are based on the performance
achieved by biological treatment and the concentration of pesticide
measured in the resultant effluent wastewaters. Where the treatment
standards are expressed as concentration-based treatment standards, the
use of other technologies to achieve these standards is not precluded
from use by this rule.
The proposed treatment standards for the wastewater forms of these
organophosphorous pesticides were based on the concentrations of
Disulfoton as measured in grab samples of scrubber water from the
incineration of K037 nonwastewaters. EPA has decided to change these
standards in the final rule based on additional performance data for a
biological wastewater treatment system submitted during the comment
period. The Agency believes that these wastewaters have concentrations
7-2
-------
2315g
Table 7-1 BOAT Nonwastewater Treatment Standards for K038. K040,
P039, P071, P089. P094. P097. and UZ35
Anttmet ic
Constituent average of Treatment
from which corrected Variability standard
Waste Regulated treat, data treat, values factor (Ave. x VF)
code constituents were transferred (ppn) (VF) (ppm)
K038
Phorate
Disulfoton
0.040
2.8
0.10
PC040
Phorate
Oisulfoton
0.040
2.8
0.10
P039
Oisu lfoton
0 isulfoton
0.040
2 8
0.10
P071
Methyl parathion
Disulfoton
0.040
2.8
0 10
P089
Parathion
Disulfoton
0.040
2.8
0 10
P094
Phorate
Disulfoton
0.040
2 8
0 10
P097
Famphur
Disulfoton
0.040
2 8
0.10
U235
tris-(2.3-Dibromopropy1
Disulfoton
0.040
2.8
0 10
phosphate)
(For any single grab sanqjle)
Table 7-2 HDAI Wastewater Treatment Standards for K036. (038. K040.
P039. P071, P089. P094. P097. and U23S
Anttmet ic
Constituent average of Treatment
from which corrected Variability standard
Waste Regulated treat, data treat, values factor (Ave. % VF)
code constituents were transferred (ppm) (VF) (ppm)
K036
Oisu lfoton
Parathion
0.0093
2.64
0.02S
K038
Phorate
Parathion
0.0093
2.64
0.025
K040
Phorate
Parathion
0.0093
2.64
0.025
P039
Disulfoton
Parathion
0.0093
2.64
0.025
P071
Hcthyl parathion
Parathion
0 0093
2 64
0 025
P089
Parathion
Parathion
0 0093
2 64
0 025
P094
Phorate
Parathion
0 0093
2 64
0 025
P09/
F amphur
Parathion
0.0093
2 64
0 025
U235
tris-(2.3-Dibronupropy 1
Pjrathion
0 0093
2 64
0 025
phosphate)
(For any canposite sample)
-------
of Parathion that are expected to be similar to constituent
concentrations in those wastewaters identified specifically as K036,
K038, K040, P039, P071, P089, P094, P097, or U235. Therefore, revised
concentration-based standards for the wastewater forms of K036, K038,
K040, P039, P071, P089, P094, P097, and U235 based on analysis of
composite samples from wastewater treatment are promulgated.
The Agency has determined that currently there are no analytical
methods that allow the measurement of the principal hazardous constituent
(organophosphorous pesticide) contained in wastes and treatment residuals
for wastes identified as K039, P040, P041, P043, P044, P062, P085, P109,
Pill, U058, and U087. Thus, the Agency is' unable to promulgate
concentration-based treatment standards for these wastes and is
promulgating methods of treatment. Although EPA prefers a concentration-
based standard (both because of the greater flexibility in choice of
technology used to achieve the standard and the greater control afforded
to ensure efficient design and operation of the chosen technology), in
the absence of analytical methods (that would measure and assure
compliance), the Agency believes that establishing a method of treatment
is the only logical alternative for BDAT. Further, EPA believes that
this is consistent with the promulgated BDAT methodology and with RCRA
section 3004(m), which authorizes the Agency to establish either levels
or methods of treatment.
Vl'-.z
7-4
-------
As discussed previously, the Agency believes that incineration
represents BDAT for the nonwastewater forms of these wastes. Besides the
fact that EPA does not currently have an analytical method for this group
of organophosphorous pesticides, EPA has not identified any organic
constituents in these wastes that could be used as a surrogate or as an
indicator compound in order to develop alternative concentration- based
standards for these wastes. Therefore, the Agency is promulgating a BDAT
treatment standard of "Incineration as a Method of Treatment" for the
nonwastewater forms of K039, P040, P041, P043, P044, P062, P085, P109.
Pill, U058, and U087.
For the wastewater forms of these organophosphorous wastes, the
Agency proposed carbon adsorption as the BDAT treatment method in
54 FR 1086 (January 11, 1989). The residual from this type of
nondestructive treatment, i.e., the spent carbon, is still considered to
be the same waste code as before treatment, and must be managed as such.
It therefore must be incinerated prior to land disposal.
It should be noted that the use of other treatment technologies prior
to carbon adsorption is not prohibited by this rule. Carbon adsorption
is often used at the end of a treatment train, after the constituent
concentrations are reduced by technologies such as chemical oxidation,
hydrolysis or biodegradation. Any nonwastewater residues from these
treatment technologies prior to and including carbon adsorption would
have to be incinerated in order to meet the treatment standard. The
wastewater effluent from carbon adsorption would be considered to meet
the treatment standard.
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As explained in Section 5.2 several commenters suggested that there
are cases where it may be preferable to incinerate the wastewater rather
than have the waste adsorbed by carbon. Thus, the Agency is promulgating
"Incineration or Carbon Adsorption as a Method of Treatment" as BDAT for
the wastewater forms of wastes identified as K039, P040, P041, P043,
P044, P062, P085, P109, Pill, U058, and U087. Spent carbon and any other
nonwastewater residuals generated upstream from a carbon adsorption unit
must meet the nonwastewater standards applicable to these wastes prior to
land disposal. Carbon adsorption units must be operated so that
breakthrough of organophosphorous compounds does not occur. Selection of
a surrogate or indicator compound of this breakthrough should be made on
a case-by-case basis.
(12 oq
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8. REFERENCES
APHA, AWWA, and WPCF. 1985. American Public Health Association,
American Water Works Association, and Water Pollution Control
Federation. Standard methods for the examination of water and
wastewater. 16th ed. Washington, D.C.: American Public Health
Associ ation.
Environ Corporation, (n.d.). Characterization of waste streams listed
in 40 CFR Section 261 waste profiles, Vol. II. Prepared for Waste
Identification Branch, Characterization and Assessment Division, U.S.
Environmental Protection Agency. Washington, D.C.: U.S. Environmental
Protection Agency.
Merck and Co. 1983. Merck index, 10th ed. Rahway, N.J.
USEPA. 1986a. U.S. Environmental Protection Agency, Office of Solid
Waste. Test methods for evaluation of solid waste; physical/chemical
methods, SW-846. 3rd ed. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1986b. U.S. Environmental Protection Agency, Office of Solid
Waste. Computer printout: Data on organophosphorous wastes. National
survey of hazardous waste treatment, storage, disposal, and recycling
facilities. Retrieved October 1988. Washington, D.C.: U.S.
Environmental Protection Agency.
USEPA. 1987. U.S. Environmental Protection Agency, Office of Solid
Waste. Generic quality assurance project plan for Land Disposal
Restrictions Program ("BOAT"). Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1988a. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for K037. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1988b. U.S. Environmental Protection Agency, 'Office of Solid
Waste. Land Disposal Restrictions for First Third Scheduled Wastes:
Final Rule. 53 FR 31157, August 17, 1988.
USEPA. 1988c. U.S. Environmental Protection Agency, Office of Solid
Waste. Methodology for developing BDAT treatment standards.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1988d. U.S. Environmental Protection Agency, Office of Solid
Waste. Treatment technologies background document. Washington, D.C.:
U.S. Environmental Protection Agency.
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