United States                Solid Waste and           EPA530-F-00-021
                Environmental Protection Agency    Emergency Response             July 2000
                                       (5305W)             http://www.epa.gov
                Office of Solid Waste

                Environmental

                Fact  Sheet
                Proposed  Rule Aims to Revise Certain

                Treatment Standards for Spent Potliners

                from  Primary Aluminum Reduction

                (K088) and Identify a New Regulatory

                Classification Scheme  for Vitrification

                Units Treating K088 Waste

                  The Environmental Protection Agency (EPA) is proposing a more
                environmentally-sound regulatory strategy for the treatment of K088 waste.  Every
                year around 100,000 tons ofK088 waste (spent aluminum potliner from primary
                aluminum reduction) is generated by the aluminum industry.  Under our existing
                Land Disposal Restrictions (LDR) program,  generators are required to treat this
                waste to meet numerical concentrations standards prior to land disposal. Current
                treatment methods, while effective in achieving these numerical standards, have
                resulted in an almost three-fold increase in waste volume. Today's proposal signals
                a new direction for the LDR program, one which fosters the use of environmentally-
                sound recycling technologies over treatment that merely prepares a waste for land
                disposal.  This proposal not only promotes the use of a technology that generates
                two usable products, fluoride dust and glass frit, it also results in the destruction of
                significant amounts of cyanide in K088 waste. As a consequence, if finalized, the
                rule will greatly reduce the volume of treated K088 residuals that are land disposed.

Background
     As a result of past litigation efforts, the Agency has an opportunity to undertake a
comprehensive re-evaluation of the entire regulatory strategy for K088.  Over the last 18 months,
we have gathered additional data and information on treatment and recycling technologies that could
possibly serve as the basis for a more permanent K088 treatment standard. We have investigated
technologies such as vitrification, gasification, and alkaline chlorination, among others. Our
emphasis has been on the overall environmental benefits of the technology.  Based on our evaluation,
we have identified a technology, vitrification, that can provide superior treatment of cyanide, an
extremely toxic hazardous constituent in K088 waste while, at the same time, recovering fluoride
and generating usable glass product.

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Action

      EPA is proposing a three-part regulatory strategy for K088 treatment - a strategy that
provides environmental protection but also flexibility with regard to regulatory compliance.  The
three basic components are:

•  revised treatment standards for cyanide and fluoride in K088 nonwastewaters that encourage
   environmentally-sound recycling of fluoride and the production of useable products;
•  identification and regulation of K088 vitrification units as RCRA Subpart X miscellaneous
   treatment units subject to appropriate air controls; and
   deregulation of certain outputs from K088 vitrification.

   Specifically, EPA is proposing a new treatment standard of 2.7 mg/L fluoride for K088
nonwastewaters, measured by a version of the Toxicity Characteristic Leaching Procedure (TCLP)
that uses deionized water as the leaching fluid (ASTM Method D3987-85 (1999)). The Agency is
also proposing to revise the treatment standards to 1.4 mg/kg for both total and amenable cyanide in
K088 nonwastewaters.

   Furthermore, the Agency is proposing to classify all K088 vitrification units as a  miscellaneous
Subpart X treatment units and is recommending that permit writers consider the recently promulgated
hazardous waste incinerator standards as the point of departure when developing a full suite of
appropriate emissions standards for these units. This is, at least  in part, because improper design,
operation, or maintenance of these units could result in emissions of toxic compounds that could
pose a threat to human health and the environment.  This regulatory approach offers implementation
flexibility so that regulatory agencies can impose only appropriate, environmentally protective
conditions on a case-by-case basis.

   In addition, in what is a logical outgrowth of this concept, the  Agency is requesting comment on
the extension of this rationale to all vitrification units, not just units processing K088. Finally, as the
last component of the K088 strategy, EPA is proposing that both  output streams (the fluoride dust and
the glass frit) from the vitrification of K088 waste be classified as products, and no longer solid
wastes,  provided certain conditions are satisfied.

For More Information
   This Federal Register notice and this fact sheet are available in electronic format on the Internet.
The notice is available at http://epa.gov/fedregstr/fdate of publication]. The fact sheet and other
documents related to this rule are at http://www.epa.gov/epaoswer/hazwaste/gener/K088.htm. For
additional information or to order paper copies of any documents, call the RCRA/Superfund Hotline
at (800) 424-9346 (toll free) or (703) 412-9810 in the Washington, D.C. metropolitan area.  The
RCRA/Superfund Hotline operates weekdays (except federal holidays) from 9:00am to 6:00pm.
Additional information may also be requested by writing to the RCRA Information Center (5305W),
U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, Washington, D.C. 20460.

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