wwsan MEMORANDUM TO: Monica Chatmon-McEaddy cc: J. Strauss S. Shwartz FROM: Laura Fargo 5254 File Scott Wolff DATE: November 8, 1989 SUBJECT: Treatment Standards for Nonwastewater and Wastewater Forms of K100 This memorandum presents the technical support and rationale for the development of treatment standards for nonwastewater and wastewater forms of K100. INTRODUCTION According to 40 CFR Part 261.32 (hazardous wastes from specific sources), waste code K100 is listed as waste leaching solution from acid leaching of emission control dust/sludge from secondary lead smelting. Treatment standards for K100 wastes were originally scheduled to be promulgated as jpart of the Third Third rulemaking. However, a treatment standard of "No Land Disposal Based on No Generation" for K100 nonwastewaters was promulgated on August 8, 1988, and was subsequently revised on May 1, 1989, (54 FR 18836) to be applicable only to "Nonwastewater forms of these wastes generated by the process described in the listing description and disposed after August 17, 1988, and not generated in the course of treating wastewater forms of these wastes [Based on No Generation]." In the proposal for the Second Third Wastes (54 FR 1056, January 11, 1989), EPA stated its intention to develop concentration-based treatment standards for all forms of K100 prior to May 8, 1990, and has since -1- 3215S ------- decided to propose to revoke the promulgated treatment standard of "No Land Disposal Based on No Generation" for K100 nonwastewaters. EPA prefers to set concentration-based treatment standards in lieu of this standard and is today proposing these for K100 nonwastewaters. Concentration-based treatment standards for all forms of K100 are proposed today based on the transfer of performance data from other hazardous wastes known to be similar in chemical and physical form to K100 wastes. INDDSTRY AFFECTED Based on available information, the Agency believes that this waste is no longer generated by the lead smelting industry. However, K100 treatment standards are still necessary for application to residues from previous disposal. WASTE CHARACTERIZATION The Agency has determined that K100 represents a single treatability group based on its expected physical and chemical composition. This group consists of two subgroups -- wastewaters and nonwastewaters. For the purpose of the land disposal restrictions mile, wastewaters are defined as wastes containing less than 1 percent (weight basis) filterable solids and less than 1 percent (weight basis) total organic carbon (TOC). Wastes not meeting this definition are classified as nonwastewaters. The Office of Water, Effluent Guidelines Division, Effluent Limitations Guidelines (ELG) reports on the secondary lead smelting industry were reviewed and were found to contain no characterization data on the K100 waste stream. The EPA Preamble on Land Disposal Restrictions for First Third Scheduled Wastes: Final Rule (FR 31138-31222), as well 3215ft -2- ------- as Che "Response to Comments Related to the First Third Wastes Treatment Technologies and Associated Performance," contain no data on K100 waste and its treatability. The only characterization data available are in a report prepared for the Waste Identification Branch of OSW (USEPA 1985). Table 1 presents these data. It should be noted that these are "synthetic waste" data based on emission control dust composition data and solubility of dust metal constituents in dilute sulfuric acid. Table 1 K100 - Waste Characterization Data BDAT constituents Hexavalent chromium Lead Cadmium Estimated concentration (mg/1) 20 60 110 Source: USEPA 1985. APPLICABLE AND DEMONSTRATED TECHNOLOGIES This section describes the applicable treatment technologies for the treatment of K100 waste. The Agency identified the applicable treatment technologies based on the estimated waste composition (see Table 1). The technologies considered to be applicable are those designed to reduce the concentration of BDAT list metals present in the treated residual and/or reduce the leachability of BDAT list metals in the treated residual. Chemical precipitation followed by dewatering of the precipitated solids is an applicable technology for the removal of the dissolved metals from K100 wastewater. Ordinarily, ion exchange would be an applicable 321Sg -3- ------- technology. However, K100 is likely to have a very high ionic strength since it is derived from acid leaching. Ion exchange is not conducive to solutions with very high ionic strengths. Additionally, the presence of hexavalent chromium indicates the need for chromium reduction to convert hexavalent chromium to trivalent chromium prior to precipitation. Dewatering of the precipitated solids results in a nonwastewater filter cake stream and a wastewater filtrate stream. The filtrate may be further processed by polishing filtration, such as multimedia filtration, to remove the remaining suspended solids. For the nonwastewater solids that are precipitated and filtered, stabilization may be used to reduce the leachability of the BDAT list metals. All of the applicable technologies are demonstrated. Hexavalent chromium reduction, chemical precipitation, and dewatering by settling and/or filtration are widely practiced as a metals treatment technology for aqueous wastes. In addition, polishing filtration is a well-documented technology for removing insoluble material from wastewater streams. Regarding treatment of the precipitated solids, stabilization of wastewater treatment sludges is well demonstrated. PERFORMANCE DATA BASE Lacking specific data on treatability of K100 wastes, EPA is considering concentration-based treatment standards for wastewater forms of K100 based on the transfer of performance data for metals precipitation from K062 wastewaters, and data for metals stabilization from F006 and K061 nonwastewaters. A. Wastewaters. The Agency has 11 data sets for treatment of metal bearing wastewaters containing hexavalent chromium, lead, and cadmium by the treatment methods of hexavalent chromium reduction, chemical precipitation, and dewatering of the precipitate. These data are -4- 3215g ------- presented in Tables 2 through 12. These metal bearing wastewaters include waste code K062, as well as other metal containing waste streams, and these data were previously used in the development of treatment standards for K062 in the First Third Final Rule (USEPA 1988b). The Agency believes that these K062 data can be used to assess the performance of these technologies for K100 wastewaters, since the untreated K062 wastewaters contain much higher metals concentrations than K100 wastewaters are expected to contain. B. Nonwastewaters. Treatment performance data are not available for K100 nonwastewaters specifically. However, performance data are available from stabilization tests on F006 and K061 nonwastewaters using various pozzolonic binders in various mix ratios. The data presented in Table 13 represent performance data developed from stabilization of F006 waste, while the data in Table 14 represent treatment of K061 wastes. These data were previously used in the development of treatment standards for F006 and K061 in the First Third Final Rule (USEPA a,c). 32156 -5- ------- Table 2 Treatment Performance Data for K062 - EPA-Coll oc tod Data Soaple Set #1 Untreated Treated Untreated Untreated waste waste K062 waste K062 waste coagiosite* (wastewater) (or/1) (¦S/l) (¦S/l) (¦s/l) Canatituant Te»|il ¦ Ho. *Ti»li1a lo. "TiMiji 1 ii Ro. S^>le Bo. 801 802 SOS 806 Arsanic 3 <1 <1 <0.1 C«UtB <5 <5 13 <0.5 Qmnim (baxsvalmt) I I 893 0.011 Chromitn (total) 1800 7000 2581 0.12 Copper 865 306 138 0.21 Lead <10 <10 64 <0.01 lickel 3200 2600 ~71 0.33 Zinc <2 <2 116 0.123 Design and Operating Data Paiiiim value Operating value pB 8-10 B I - Color interferonce. * The uxrtraotad waste composite ia a Mixture of tha untreated K062 waste atrea ibno oo this table, »' ""fl with other noo-KOSZ waata streams. Source: USEPA 1888b. 3215g -6- ------- Table 3 Treatment Performance Data for K062 - EPA-Co 11 ec tad Data Saaq>le Sat #2 Untreated Treated Untreated Untreated waste waste K0B2 waate K062 waate canqiosite* (wastewater) (BR/1) (¦8/1) (¦8/1) (¦s/D Constituent TT«Hile lo. Staple Bo. Sasple lo. Saaple Ho. 801 802 813 814 Arsenic 3 <1 <1 <0.1 Catfain <5 <5 10 <0.5 Chriaia (hexavalent) I I 807 0.12 Chrcaiia (total) 1800 7000 2270 0.19 Copper 865 308 133 0.15 Lead <10 <10 54 <0.01 ¦ickel 3200 2600 470 0.33 Zinc <2 <2 4 0.115 Design and Operating Data Daslicn value 02«rating_valuo pB 8-10 0 I • Color interference. 4 The untreated waste composite la a mixture of the untreated K062 waste itram shown on this table, along with other non-1062 waste streams. Source: DSEPA 1988b. 32138 -7- ------- Table 4 Treat twit Perforance Data for K062 - EPA-Collected Data *Iiib|i1ii Sat #3 Untreated Treated Untreated Untreated waste waste 1062 waste K062 waste composite" (wastewater) (¦K/l) (ng/1) (¦K/l) (¦g/1) Constituent ii Bo. Sanple Bo. *iiw|ile Bo. Staple Ho. 817 802 821 822 Arsenic 3 <1 <1 <0.1 CsUia <5 <5 S <0.5 Oralia (hexovalant) I I 775 I Chranlan (total) 1700 7000 1980 0.20 Copper 425 306 133 0.21 Lead <10 <10 <10 <0.01 ¦lckel 100310 2600 16330 0.33 Zinc 7 <2 3.9 0.140 Design and Operating Data Design value Operat<"fi pB a-10 10 I • Color in tarlexones. a Iha untreated waste co^rosito Is a mixture of the untreated 1062 waste streans ¦boa an this table, along with other nao-K062 waste streaae. Source: DSEPA 1988b. 321Sg -8- ------- Tab la 5 Treataant Perfomance Data for K062 - EPA-CoLiected Data Sample Sat #4 Untreated Treated Untreated Untreated Untreated waste waste 1062 waste 1062 waste 1062 waste ccopoaite* (wastewater) (¦S/1) (¦S/1) (¦6/1) (ng/1) (¦S/1) Coostituaot Soqile lo. Sample Bo. Sample Bo. Sample Ho. Sample Bo. 827 802 817 829 830 Arsenic 2 <1 3 <1 <1 Cackniw <5 <5 5 <5 <0.5 Chraim (haxaralent) 1 I I 0.6 0.042 dumlia (total) 142 7000 1700 536 0.10 Copper 42 306 425 88 0.07 Lead <10 <10 <10 <10 <0.01 Bickel 830 2600 41000 6610 0.33 Zinc 3 <2 7 84 1.62 Design and Operating Data gaalQjalua Operating value pfl 8-10 9 I • Color interference. a Ttaa untreated vaat* caqnsite la a aixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste struma. Source: DSEPA 1088b. 3215g -9- ------- Tabla 6 Treatment Perfomonce Data for K0B2 - EPA-Collected Data Ssq>le Sat #5 Constituent Untreated K062 waate (¦B/l) Sapla Bo. 801 Untreated K0S2 waste (os/1) Soapla Bo. 802 Untreated L0B2 waste (¦B/l) Soq>le Bo. 817 Untreated waste composite" (¦B/l) Sample Bo. 837 Treated waste (wastewater) (ns/1) Staple Bo. 838 Arsenic 3 <1 3 <1 <0.1 CaMia <5 <5 S <5 <0.5 Chrtmiia (hazavalsot) I 1 I 917 0.058 Chromita (total) 1800 7000 1700 2236 0.11 Copper 865 306 *25 01 0.14 Lead <10 <10 <10 18 0.01 lickel 3200 2600 41000 1414 0.31 Zinc <2 <2 7 71 0.125 Daaign and Operating Data D»»l«n value "p*"*'"!! value pB 8-10 8 I • Color interference. * The untreated waste ca^oaite is a mixture of the untreated 1062 waste atreoaa shorn an thia table, ~*B with other oon-KD62 waate itraiaa. Source: DSEPA 1988b. 3215g -10- ------- Table 7 Treatment Perfomonce Data for K062 - EPA-Collected Data S«ple Sat #6 Ontraatad Treated Untreated Ontraatad waata waata 1082 waata K062 waata composite* (wastewater) (¦B/l) (¦ft/1) (¦8/1) (¦S/I) Cooatituant Saqila Bo. Sople Bo. Staple Ho. Sample Bo. 801 802 845 846 Arsonic 3 <1 <1 <0.1 CadBloa <5 <5 <5 <0.5 amnios (heuvalant) I I 734 I OuiHlia (total) 1800 7000 2548 0.10 Copper 863 308 140 0.12 Load <10 <10 <10 <0.01 ¦ickel 3200 2600 588 0.33 Zinc <2 <2 4 0.095 Dw<1B and Operating Data D«aiiai viU.ua Qparat'"fi »»!¦¦« pfl 8-10 8 I • Color inUrfsrenot. ° Tha untreated waste coqnaiU la a aixture of the untreated K062 waste atreaaa ¦bna ao thla tab la, alms with otbar noo-U62 waata atraaaa. Source: OSEPA 1988b. 3215g -11- ------- Tab 1a 8 Treataant Parfomonce Data for K062 - EPA-Collected Data Saq>le Sat #7 Untreated Treated Ontraatad Untreated waste waste K062 mate K062 waste coaqnaite" (wastewater) (ng/1) (¦B/l) (ob/1) (ag/1) Cooatltuant Saapla Bo. Staple Ho. Soq>le Bo. Sample Bo. 801 802 853 854 Arsenic 3 <1 <1 <0.1 Cafein <5 <5 10 <0.5 dinalia (hazavalant) I I 769 0.12 Chronlia (total) 1800 7000 2314 0.12 Copper 863 306 72 0.16 Lead <10 <10 108 <0.01 Bickel 3200 2600 426 0.40 Zinc <2 <2 171 0.115 Design and Operating Data Design value value pB 8-10 9 I ¦ Color interference. a Tbe untreated «ast* ctafOilU la a aixtore of tbe untreated 1062 waate Dtrons ¦boa on thli table, along witb other non-K062 waata itnoi. Source: DSEFA 1988b. 3215g -12- ------- Table 0 Treatment Fubnmc* Data for K062 - KPA-Collected Data "*f 1 ° Sat #8 Untreated Treated Untreated Untreated waate waate K062 waate K062 waste canpoaite* (wastewater) (>8/1) (¦8/1) (¦g/1) (¦s/l) Constitoant ImjiI ¦ lo. Simple Bo. Sample Bo. Saopla Ho. 839 801 861 862 Arsenic <1 3 <1 <0.1 Caitaiia <5 <3 <3 <0.3 Chroniiai (hazovalent) 0.220 I 0.13 <0.01 Chroalia (total) 13 1800 831 0.13 Copper 131 883 217 0.16 Load <10 <10 212 <0.01 ¦ickel 90 3200 669 0.36 Zinc 7 9 131 0.13 Design at td Operating Data Dealm value Operation value pB 8-10 9 I - Color interference. * The untraatad waate ccnposlta la a Mixture of the untreated K082 waste streans abon an this table, along with other noo-K062 waste stress. Source: OSEPA 1988b. 3213g -13- ------- Table 10 Treatment Performance Data for K062 - EFA-Collected Data Sample Set #8 Qntreated Treated Ontraated Untreated Untreated waste waste K062 waata 1062 waste K062 waste composite" (wastewater) (og/1) (¦g/1) (¦g/1) (ng/1) (og/1) Constituent Sapl* Bo. Saq>le So. Tiwjil ii Bo. Tmijil ii Bo. Simple Bo. 867 801 802 868 870 Afeae&ic <0.1 3 <1 <1 <0.1 Cadaiia <0.3 <5 <5 <5 <0.5 Qraaiia (hexavalent) 0.078 I I 0.07 0.041 Chroaita (total) 6 1800 7000 838 0.10 Copper 5 863 306 225 0.08 Lead <1 <10 <10 <10 <0.01 Bickel 4 3200 2600 840 0.33 Zinc 0.4 <2 <2 5 0.06 Design and Operating Data DegiKn value Operation value pfl 8-10 10 I • Color interference. " lb* untreated waste caefwaite is a mixture of the untreated K062 waste itruas sbown on tbia table, along with otbar non-K0B2 waste atreaaa. Source: OSEPA 1888b. 3215g -14- ------- Table 11 Treatment Performance Data for K062 - EPA-Collected Data Simple Sat #10 Ontreatad Treated On treated waste waste 1062 waste cnposite* (wastewater) (*/l) tas/1) (¦B/l) Constituent TTiMjil n Bo. S^>Le Ho. Ssople Bo. 801 883 862 Arsenic <3 <1 <0.10 Cactoita <5 <5 <0.5 Chroeiia (hexovalant) I 0.08 0.106 Chrcmitza (total) 1800 393 0.12 Copper 863 191 0.14 Lead <10 <10 <0.01 ¦ickel 3200 712 0.33 Zinc <2 3 0.070 Design and Operating Data Desisn value Ooeratinjc value PB 8-10 9 I » Color interference. 8 The untreated waste cmpoaita la a aixture of the untreated K062 waste stress shown an this table, along with other mm-K0B2 waste strains. Source: DSEPA 1988b. 3215g -15- ------- Table 12 Treatment Performance Data for K062 - EPA-Co 11 acted Data Soople Set #11 Untreated Treated Dntreatod Untreated waste waste K062 waste K062 waste cn^iuiilte* (wastewater) (¦B/l) (¦B/l) (¦B/l) (¦B/l) Constituent SwrlT Bo. Staple So. Staple Wo. Saqile So. 801 839 893 894 Arsenic 3 <1 <1 <0.10 Cadsiia <5 <5 23 <5 Chraaita (haxavalent) I 0.220 0.30 <0.01 Chrcoiia (total) 1800 IS 617 0.18 Copper 865 151 137 0.24 Lead <10 <10 136 <0.01 ¦ickel 3200 90 382 0.39 Zinc <2 7 135 0.100 Design and Operating Data Den lien value Operate "fi »»1"» pH 8-10 9 I - Color Interference. a The untreated waste co^nsite la a mixture of the untreated K082 waste s trams shown on this table, along with other non-K0B2 waste streone. Source: DSEFA 1088b. 3215g -16- ------- 326ag Table 13 Treatment Perforaance Data for Stabilization of F006 Nonwastewater Source Mix rat1ob Metal concentrations (new) Bar inn CacfaluB Chrtmiua Copper Lead Nickel Silver Zinc Unknown Unstablllzed As received Tap Stabilized Tap 0.2 435 0.71 0.05 1560 0.16 0.03 Auto part Manufacturing Unstablllzed As received TCLP Stabilized TCLP 0.5 31.3 2.21 0.01 755 0.76 0.45 7030 638 0.27 409 10.7 0.39 989 22.7 0.03 6.62 0.14 0.06 4020 219 0.01 Aircraft overhauling Unstablllzed As received Tap Stabilized TCLP 0.2 85.5 1.41 0.34 67.3 1.13 0.06 716 0.43 0.09 259 1.1 0.27 631 5.41 0.03 Zinc plating Unstabilized As received Tap Stabilized TCLP 0.5 17.2 0.84 0.25 1.30 0.22 0.01 1510 4.6 0.21 37 0.52 0.02 9.05 0.16 0.05 90.200 2050 0.04 Unknown Unstabilized As received Tap Stabilized Tap 0.5 14.3 0.38 0.21 720 23.6 0.01 12,200 25.3 0.44 160 1.14 0.31 701 9.78 0.04 25.900 867 0.03 ------- 3265g Table 13 (continued) Source Nix ratio" Bariua Cadniua Metal concentrations (pan) Chroniun Copper Lead Nickel Silver Zinc Snail engine nanufacturlng llnstabilized As received TCLP Stabilized TCLP 0.5 7.28 0.3 0.01 3100 38.7 0.89 1220 31.7 0.31 113 3.37 0.39 19.400 730 0.06 4.08 0.12 0.06 27.800 1200 0.040 Circuit board Manufacturing Unstabilized As received TCLP Stabilized TCLP 0.5 5.39 0.60 0.01 42,900 360 1.41 10.600 8.69 0.45 156 1.0 0.41 13.000 152 0.11 120 0.62 0.020 Unknown Unstabilized As received Tap Stabilized TCLP 0.5 15.3 0.53 0.294 5.81 0.1B 0.01 17.600 483 0.35 169 4.22 0.40 23,700 644 0.04 8.11 15,700 0.31 650 0.06 0.020 Unknown Unstabilized As received TCLP Stabilized Tap 0.5 19.2 0.28 0.087 27,400 16.9 0.50 24,500 50.2 0.29 5,730 16.1 <0.02 322 1.29 <0.01 aAdjusted analytical results (referred to as accuracy-corrected concentrations) used for comparing the performance of one technology to that of another and for calculating treatment standards for those constituents to be regulated (USEPA 1988a). b weight of reagent Nix ratio = . weight of waste Source: USEPA 1988a. ------- Table 14 Summary of Treatment Performance Data for Stabilization of K061 Nonwastewater Using a Lime/Flyash Binder (EPA Collected Data) Untreated waste Treated waste Constituents Total (ppm) TCLP (mg/1) TCLP (mg/1) Antimony 294 0.040 <0.050 Arsenic 36 <0.010 <0.010 Barium 238 0.733 0.431 - 0.500 Beryllium 0. 15 <0.001 <0.001 Cadmium 481 12.8 0.033 - 0.073 Chromium 1,370 <0.007 0.053 - 0.093 Copper 2,240 0.066 <0.004 - 0.015 Lead 20,300 45.1 0.066 - 0.150 Mercury 3. ,8 0.0026 0.0016 - o.oo: Nickel 243 0.027 <0.012 Selenium <5. 0 <0.050 <0.025 Silver 59 0.021 <0.003 Thallium <1. 0 0.038 0.011 - 0.014 Vanadium 25 <0.006 0.080 - 0.089 Zinc 244,000 445 0.179 - 0.592 Oil and grease 282 Sulfates 8,440 Chlorides 19,300 TOC 4,430 Source: USEPA 1988c. -19- 3215g ------- IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT') This section presents the rationale for the determination of best demonstrated available technology (BDAT) for nonwastewater and wastewater forms of K100. The Agency examined all the available treatment performance data for the demonstrated technologies to determine which is best. Treatment performance data are available for metal bearing wastewaters containing K062 waste that is believed to be similar to K100 wastewaters. For K100 nonwastewaters, performance data are available from stabilization tests on F006 and K061 nonwastewaters. A. Vastevater. Available treatment performance data presented in Tables 2-12 for treatment of K062 wastewaters by chromium reduction, chemical precipitation, and filtration show that this treatment is effective. Total chromium was reduced from 2,581 mg/1 to 0.12 mg/1; cadmium from 13 mg/1 to <0.5 mg/1; nickel from 471 mg/1 to 0.33; and lead from 64 mg/1 to <0.01 mg/1. The Agency has determined that the data collected from treatment of K062 wastewaters represents a well-designed and well-operated system and therefore may be used to compare treatment performance of demonstrated technologies. Based on the evaluation of the available treatment performance data and other information, the Agency believes that the treatment train consisting of hexavalent chromium reduction, chemical precipitation, and settling and/or filtration represents BDAT for K100 wastewaters. B. Nonwastewaters. EPA compared the F006 wastes and K061 wastes with regard to metals concentrations. In general, both K061 nonwaste- waters and F006 nonwastewaters contain similar metal constituents but F006 has several BDAT list metals at higher concentrations. Specifically, chromium is present in the untreated F006 wastes at concentrations as high as 42,900 ppm and in K061 wastes as high as 1,370 ppm; lead is 3215g -20- ------- present in F006 in concentrations as high as 24,500 ppm and in K061 wastes at 20,300 ppm; and cadmium is present in F006 wastes at concentrations as high as 720 ppm and in K061 wastes as high as 481 ppm. Additional characterization of the wastes (USEPA 1988a,c) show that F006 wastes have higher concentrations of organics than K061, which would tend to make the F006 waste more difficult to treat by stabilization techniques based on waste characteristics that affect the stabilization process. Importantly, K100 nonwastewaters would be formed by chemical precipitation processes similar to the processes that form F006 nonwastewaters. K061 nonwastewaters generally do not result from chemical precipitation. Therefore, K100 nonwastewaters are expected to be more similar to F006 than K061. Although no waste characterization data for K100 nonwastewaters are available, based on the above reasons, the Agency believes that the treatment levels achieved for cadmium, lead, and chromium in the F006 wastes can also be achieved for K100. Accordingly, EPA is using F006 performance data to establish treatment standards for K100 nonwastewaters. The performance data that EPA used in assessing substantial treatment are shown in Table 13. As shown, stabilization achieved substantial reductions in the leachate value for all of the metals selected for regulation. (The next Section presents a discussion of constituents selected for regulation.) Specifically, TCLP leachate concentrations in the treated waste were no more than 0.06 mg/1 for cadmium, 1.41 mg/1 for chromium, and 0.41 mg/1 for lead. The Agency believes the reduction in the range and magnitude of the various hazardous constituents to be substantial. Stabilization has been determined to be demonstrated and best, has provided substantial treatment, and is commercially available; therefore, stabilization represents BDAT for K100 nonwastewaters. 3215s -21- ------- Selection of Regulated Constituents The previous section explained the Agency's selection of the best demonstrated and available treatment technology for treating K100 wastes. The constituents chosen by the Agency for regulation are those expected to be found in untreated wastes at treatable concentrations for the selected BDAT. The metals expected to be found in treatable concentrations in the untreated K100 waste are chromium, lead, and cadmium (based on Table 1 data). Each of these three metals is chosen for regulation in K100 wastes. Development of Treatment Standards This section presents the treatment standards for the regulated constituents described previously. A description of the rationale and procedures for calculating treatment standards for wastewaters is presented in the K062 background document (1988b). For nonwastewaters, the rationale for the chosen standards is presented in the F006 background document (1988a). The BDAT treatment standards presented in this section (1) are reflective of treatment performance data from a well-designed and well-operated treatment system, (2) are adjusted for analytical accuracy, and (3) have been adjusted for variability caused by treatment, sampling, and analytical techniques and procedures. A. Wastewaters. EPA compared the K062 wastewaters and K100 waste stream shown in Table 1 with regard to concentrations of metals. In general, both K100 wastewaters and K062 wastewaters contain similar metal constituents. As noted earlier though, K062 wastewaters have BDAT list metals at higher concentrations than do K100 wastewaters. Therefore, EPA would expect the K062 wastewaters to be more difficult to treat effectively by the treatment system consisting of hexavalent chromium reduction, chemical precipitation, settling, and/or filtration. 3215g -22- ------- Further, based on the available data relative to waste characteristics, the Agency has no reason to believe that the treatment levels achieved for K062 wastewaters cannot be achieved for K100 wastewaters. Accordingly, EPA is using the K062 wastewater performance data for hexavalent chromium reduction, chemical precipitation, and settling and/or filtration to establish treatment standards for K100 wastewaters. Therefore, the Agency is transferring the treatment performance data from the treatment train for K062 wastewaters to K100 wastewaters. The 11 data sets for treatment of K062 wastewaters by hexavalent chromium reduction, chemical precipitation, and dewatering of the precipitate were determined to represent treatment by a well-designed and well-operated treatment system (USEPA 1988b). One treatment data set for cadmium was rejected (Sample Set #11) because of an artificially high detection limit of 5 mg/1, which deviated from the other 10 data points' detection limits of 0.5 mg/1. The remaining analytical data sets for this treatment system were corrected for analytical recovery by multiplying the data by their respective correction factors. An arithmetic average of concentration levels for each regulated constituent and a variability factor for each regulated constituent were then calculated. The treatment standard for each regulated constituent was calculated by multiplying the average accuracy corrected data by the appropriate variability factor. An expanded description of the calculation of these treatment standards is presented in the K062 background document (USEPA 1988b). Table 15 shows the calculations for the three metals regulated for K100 wastewaters. For the BDAT list metal constituents, treatment standards in the wastewater reflect the total constituent concentration. The units for the total constituent concentration are mg/1 (parts per 3215g -23- ------- Table 15 Calculation of the Treatment Standards for the Regulated Constituents - Treated Wastewater Regulated constituent (correction factor) Average corrected concentration (mg/1) Number Varia- Treatment of bility standard samples Average factor (mg/1) Cadmium (1.15) <0.575 <0.575 <0.575 <0.575 <0.575 <0.575 <0.575 <0.575 <0.575 <0.575 10 0.575 2. 8C 1.61 Chromium (total) (1.47) 0.1765 0.1765 0.2941 0.1471 0.1618 0.1471 0.1765 0.2206 0.1471 0.1765 0.2647 11 .1898 1.69 0.32 Lead (1.316) <0.0132 <0.0132 <0.0132 <0.0132 0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 11 0.0132 2.8* 0.04 aFor cases in which all values are at or below the detection limit, the variability factor is taken as 2.8. -24- 3215g ------- million on a weight-by-volume basis) for the wastewater. If the concentrations of the regulated constituents in the K100, as generated, are lower than or equal to the concentration limits established in BDAT treatment standards, then treatment is not necessary as a prerequisite to land disposal. B. Nonwastewaters. Specifically, EPA believes that the data on stabilization of F006 waste can be used to assess treatment performance for chromium, cadmium, and lead in K100 nonwastewaters. The data presented for stabilization of F006 nonwastewaters (see Table 13) has been evaluated by EPA to ensure that any data representing poor design and poor operation were deleted and that all data were adjusted for analytical accuracy. Using the accuracy corrected data, EPA developed treatment standards by averaging the performance data for each constituent and then multiplying the average value by a variability factor that accounts for variations in technology performance, waste characteristics, and laboratory analysis. An expanded description of the calculation of these treatment standards is presented in the K062 background document. Table 16 shows the calculations for the three metals regulated for K100 nonwastewaters. For the BDAT list metal constituents, treatment standards in nonwastewater reflect the concentration of constituents in the leachate from the Toxicity Characteristic Leaching Procedure (TCLP). The units for the leachate concentration are mg/1 (parts per million on a weight-by-volume basis). If the concentrations of the regulated constituents in K100 TCLP leachate, as generated, are lower than or equal to the limits set by the BDAT treatment standards, then treatment is not necessary as a prerequisite to land disposal. 3215g -25- ------- Table 16 Calculation of the Treatment Standards for the Regulated Constituents -- Treated Nonwastewater Cadmium Chromium Lead Concentration 0.01 0.45 0.39 (mg/1) 0.06 0.09 0.39 0.01 0.44 0.41 0.01 0.89 0.40 0.01 1.41 0.29 0.01 0.01 Average 0.018 0.66 0.37 Number of samples Variability factor Treatment standard (mg/1) 3.72 7.94 1.37 0.066 5.2 0.51 32138 -26- ------- References USEPA. 1985. U.S. Environmental Protection Agency. Characterization of Waste Streams Listed in 40 CFR Section 261 Waste Profiles. Vol. 11. Prepared by Environ Corporation for Waste Identification Branch, Characterization and Assessment Division, U.S. Environmental Protection Agency. USEPA. 1988a. Final Best Demonstrated Available Technology (BDAT) Background Document for F006. August 1988. Washington, D.C.: U.S. Environmental Protection Agency. EPA/530-SW-88-031L. USEPA. 1988b. Final Best Demonstrated Available Technology (BDAT) Background Document for K062. August 1988. Washington, D.C.: U.S. Environmental Protection Agency. EPA/530-SW-88-031E. USEPA. 1988c. Final Best Demonstrated Available Technology (BDAT) Background Document for K061. August 1988. Washington, D.C.: U.S. Environmental Protection Agency. EPA/530-SW-88-031D. USEPA. 1989. U.S. Environmental Protection Agency, Office of Solid Waste. Treatment Technology Background Document. Washington, D.C.: U.S. Environmental Protection Agency. 321Sg -27- ------- |