BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT FOR
PHTHALATE WASTES
Robert April, Chief
Treatment Technology Section
larry Rosengrant
Project Manager
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
June 1989
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REPORT DOCUMENTATION
PAGE
1. KEPO«T NO.
EPA/530-SW-89-048H
2.
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1. Kaclptant'* Aacaaaian Me.
19 2 2 14 5 lllS
A. Tktla and SuMRta
Best Demonstrated Available Technology (BOAT)
Background Document for Phthalate Wastes
1 "MnTlSSS
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J. Autftorta]
Robert April/Larry Rosengrant, 0SW
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U.S. EPA
Office of Solid Waste
401 M Streeti SW
Washington# DC 20460
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10. Protact/Tatk/Wart Itott Ma.
11. Contract to or QraM(O) Na.
(0 68-0-7053
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U.
M. Bttaalamantary Motaa
1*. Matrsct (UmtC 100 wan*) I
This document provides the Agency's technical support for selecting and developing
treatment standards for the constituents to be regulated in the phthalate wastes.
Sections 2 thru 7 present waste-specific information for the K023, K093, and
K094 wastes. Section 8 presents a discussion of the development of treatment
standards for those phthalate wastes designed as U wastes (U028, U069, U088,
U102, U107,and 0190).
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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, Chief, Treatment Technology
Section, Waste Treatment 8ranch, served as the EPA Program Manager during
the preparation of this document and the development of treatment
standards for phthalate wastes. The technical project officer for the
phthalate wastes was Mr. Larry Rosengrant. Mr. Nandan Kenkeremath served
as legal advisor.
Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Assistant Program Manager; Mr. Stephen
Schwartz, Task Manager; Mr. Sanjeev Aggarwal, Staff Engineer; Ms. Barbara
Malczak, Technical Editor; and Ms. Sally Gravely, Project Secretary.
Mr. Alan Corson of Jacobs Engineering Group and Mr. Mark Hereth of Radian
Corporation assisted in the review of the document.
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TABLE OF CONTENTS
Section Page
1. INTRODUCTION 1-1
2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industry Affected and Process Description 2-1
2.1.1 K023 Waste 2-1
2.1.2 K093 and K094 Wastes * 2-2
2.2 Waste Characterization 2-4
2.2.1 K023 Waste 2-4
2.2.2 K093 and K094 Wastes 2-8
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 (BDAT) 5-1
5.1 Nonwastewaters 5-3
5.2 Wastewaters 5-4
6. SELECTION OF REGULATED CONSTITUENTS 6-1
5.1 Identification of Major Constituents in the
Untreated Waste 6-1
6.2 Constituents Selected for Regulation 6-2
7. DEVELOPMENT OF BDAT TREATMENT STANDARDS I*..' 7-1
8. U WASTE CODES 8-1
8.1 Development of Treatment Standards 8-2
9. REFERENCES 9-1
i i i
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LIST OF TABLES
Table Page
1-] BDAT Treatment Standards for K023, K093, K094, and U190
Wastes 1-4
1-2 BDAT Treatment Standards for U Phthalates (U028, U069, U088,
U102, and U107) 1-4
2-1 Facilities That May Generate K023, K093, and K094
Wastes 2-5
2-2 K023 - Waste Composition Data 2-7
2-3 K093 - Waste Composition Data 2-9
2-4 K094 - Waste Composition Data 2-10
7-1 Calculation of BDAT Treatment Standards for K024 7-4
7-2 BDAT Treatment Standards for K023, K093, and K094 7-5
8-1 Number of Facilities That May Generate U028, U069,
U088, U102, U107, and U190 in Each EPA Region 8-3
8-2 BDAT Treatment Standards for U Phthalates ^028, U069, U088,
U102, U107, and U109, Respectively (Nonwastewaters) 8-13
8-3 BDAT Treatment Standards for U Phthalates U028, U069, U088,
U102, U107, and U190, Respectively (Wastewaters) 8-13
i v
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LIST OF FIGURES
Figure Page
2-1 Schematic Diagram of the Generation of K023 2-3
2-2 Schematic Diagram of the Generation of KQ93 and K094 2-6
v
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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
promulgating treatment standards based on the best demonstrated available
technology (BDAT) for the waste treatability group identified as
phthalate wastes. This treatability group includes wastes identified in
40 CFR 262.32 as K023. K093, and K094 and in 40 CFR 261.33 as U028, U069,
U088, U102, U107, and U190. Compliance with these BDAT treatment
standards is a prerequisite for the placement of these wastes in units
designated as land disposal units according to 40 CFR Part 268. 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 the phthalate wastes. Sections 2 through 7 present
waste-specific information for the K023, K093, and K094 wastes.
Section 2 presents the number and location of facilities affected by the
land disposal restrictions, the waste-generating process, and Jthe waste
characterization data. Section 3 presents the technologies used to treat
the 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. Treatment
standards are determined in Section 7. Section 8 presents a discussion
2603
1-1
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of the development of treatment standards for those phthalate wastes
designated as U wastes (U028, U069, U088, U102, U107, and U190).
The BDAT program and promulgated methodology are more thoroughly
described in two additional documents: Methodology for Developing Best
Demonstrated Available Technology (BDAT) Treatment Standards (USEPA
1989b) and Generic Quality Assurance Project Plan for Land Disposal
Restrictions Program ("BDAT") (USEPA 1987). The petition process to be
followed in requesting a variance from the BDAT treatment standards is
discussed in the methodology document.
It is EPA's understanding that six facilities produce phthalic
anhydride. The Agency is proposing to regulate one organic constituent
in both nonwastewater and wastewater forms of K023, K093, and K094
wastes. (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 proposed treatment standards for
nonwastewaters.)
BDAT treatment standards for wastewaters and nonwastewaters for K023,
K093, and K094 (see Table 1-1) have been directly transferred from the
The term "total suspended solids" (TSS) clarifies EPA's previously used
terminology of "total solids" and "filterable solids." Specifically, the
quantity of 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, 16th Edition (APHA, AWWA, and WPCF
1985).
2803
1-2
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treatment standards for K024 wastes (covered under the First Third BOAT
list of hazardous wastes). Table 1-2 presents BOAT treatment standards
for wastewaters and nonwastewaters for U phthalates (U028, U069, U088,
U102, U107, and U190), which have also been transferred from the
treatment standards for K024 wastes. These treatment standards are based
on total concentration analyses of the ash residues and the scrubber
water generated during rotary kiln incineration of K024 waste. If the
concentrations of the regulated constituents, as generated or as present
in the treatment residuals, are lower than or equal to the proposed BDAT
treatment standards, then treatment is not necessary as a prerequisite to
land disposal.
2803
1-3
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Table 1-1 BDAT Treatment Standards for K023, K093, K094, and U190 Wastes
Maximum for anv sinale arab sample
Nonwastewater
Wastewater
Total TCLP leachate
Total
Constituent
concentration concentration
concentration
(mg/kg) (mg/1)
(mg/1)
Semivolatile orqanics
Phthalic anhydride
(measured as phthalic acid)3 28 NA 0.54
NA = Not app1icable.
aThis constituent is regulated as an indicator for phthalic anhydride,
which cannot be easily analyzed because it rapidly hydrolyzes and
converts to phthalic acid by absorbing moisture.
Table 1-2 BDAT Treatment Standards for U Phthalates
(U028, U069, U088, U102, and U.07)
Maximum for any single grab sample
Nonwastewater Wastewater
Total TCLP leachate Total
Waste Constituent concentration concentration concentration
Code (mg/kg) (mg/1) - (mg/1)
U028
Bis- (2-ethylhexyl)
phthalate
28
NA
0.54
U069
Di-n-butyl phthalate
28
NA
0.54
U088
Diethyl phthalate
28
NA
0.54
U102
Dimethyl phthalate
28
NA
0.54
U107
Di-n-octyl phthalate
28
NA
0.54
2803
1-4
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2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION
The purpose of this section is to describe the phthalic anhydride
industry affected by the land disposal restrictions for K023, K093, and
K094 and to present available characterization data for these wastes.
Under 40 CFR 261.32, wastes identified as K023, K093, and K094 are
specifically generated in the production of phthalic anhydride and are
1isted as follows:
K023: Distillation light ends from the production of phthalic
anhydride from napthalene.
K093: Distillation light ends from the production of phthalic
anhydride from ortho-xylene.
K094: Distillation bottoms from the production of phthalic anhydride
from ortho-xylene.
The Agency has determined that these listed wastes (K023, K093, and
K094) represent a single waste treatability group based on their similar
chemical characteristies. The Agency has examined the source of the
wastes, the specific similarities in waste composition, applicable and
demonstrated treatment technologies, and attainable treatment performance
in order to support the approach that these wastes represent a single
9
treatability group.
2.1 Industry Affected and Process Description
2.1.1 K023 Waste
The listed waste K023 is generated in a distillation column as light
ends during the production of phthalic anhydride from napthalene in the
organic chemical industry. The Agency estimates that only one facility
currently uses this process and may generate K023 waste. This facility,
2-1
2802g
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which is located in the State of Illinois (EPA Region V), generates
approximately 300 tons of K023 waste per year.
Phthalic anhydride is manufactured by a process that uses a vaporized
napthalene and air mixture fed into a fixed-bed reactor containing a
vanadium pentoxide catalyst. The naphthalene is oxidized to phthalic
anhydride, carbon dioxide, and water vapor at a temperature of about
350°C. These gases pass through a vapor cooler that reduces the gas
temperature to just below the dew point of the gases (126°C). The
condensed liquid is then routed into crude phthalic anhydride storage.
The crude phthalic anhydride is subsequently heated at atmospheric
pressure in a distillation column to dehydrate traces of phthalic acid
and to convert other chemicals to compounds having higher boiling points,
which can be separated from the product during distillation. Other
chemicals are added to shorten the time required for purification. These
chemicals include sodium carbonate, sodium hydroxide, or a material to
tie up naphthoquinone in a polymer state so that it can be easily removed
from the product. The light ends from the distillation column constitute
the waste stream K023. Figure 2-1 is a process schematic of the
manufacture of phthalic anhydride and the generation of the listed waste
K023.
2.1.2 K093 and K094 Wastes
During the production of phthalic anhydride using ortho-xylene as
feed material, the listed waste K093 is generated in a distillation
column as light ends and the distillation bottoms are the listed waste
2-2
28Q2g
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IIAPII1IIALEIIE t|
FIKED
OEuntAcion
Ain—
Jiiiti!
UJ
CAIAIYSI
ntCYClE
CI I IDE
SIOIIAUE
nitinEAiMEur
1AI4K
I
iKtlll
EIIIIS
(K023J
UlSIIILAIIUII
CXXUMHj
T
PIII|IAUC
~ AilllYliniDE
nioiHjci
OOIIOMS
Figure 2-1 Schematic Diagram of the Generation of K023.
*
(Phthalic Anhydride Production Using Napthalene as Feed)
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K094. The Agency estimates that six facilities may generate KQ93 and/or
K094. These facilities are listed on Table 2-1. Approximately
1,000 ton/yr of K093 and K094 wastes (combined) are generated by these
six facilities {USEPA 1986).
Phthalic anhydride can be manufactured by the vapor phase oxidation
of ortho-xylene. Ortho-xylene is mixed with air and fed to a fixed-bed
tubular reactor containing vanadium pentoxide catalyst. Phthalic
anhydride is formed by the following reaction:
C&H4(CH3)2 302 -» CgH^CO^O + 3H2O.
The crude reactor effluent is condensed and sent to a distillation
column, where the light ends are removed as K093 waste. The stripped
phthalic anhydride is then distilled in a second column, where the heavy
ends or bottoms are removed as K094. Figure 2-2 is a process schematic
of the manufacture of phthalic anhydride and the generation of the listed
wastes K093 and K094.
2.2 Waste Characterization
2.2.1 K023 Waste
All waste characterization data available to the Agency^for K023
waste are presented in Table 2-2. The table shows the major constituents
in the waste and their approximate concentrations. The percent
concentration of each major constituent in the waste was determined from
best estimates based on chemical analyses and discussion with the one
known generator. At least 87 percent of the waste is composed of the
BDAT list constituent phthalic anhydride. Usually, less than 0.5 percent
2-4
2802g
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2 7 71 g
Table 2-1 Facilities That Hay Generate K023, K093, and K094 Wastes
Name of faci1ity
Capacity (10® lb/yr)
of phthalic anhydride
product
Raw nuterial
EPA
region
BASF Corporation, Kearny. HJ
175
ortho-xylene
II
Exxon Corporation. Baton Rouge, LA
220
ortho-xylene
VI
tappers Ccnpany, Cicero, 11
125a
Coal tars--
V
naphthalene
100
ortho-xylene
Stepan Company. Hillsdale. 1L
170
ortho-xylene
V
Sterling Chemical Co.. lexas City, TX
165
ortho-*ylene
VI
Tenn-USS Chemical Co.. Pasadena, TX
210
ortho-xylene
VI
aThia unit can also be operated on ortho-xylene feed.
Reference: SRI 1988.
2-5
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ORTHO-XYLENE
ICS
—1-7+
? | FIXEO-
' DEOnEAGIOn
Ain~i
U
J
HI El
¥
—~
CATALYST
flECYCie
itciir
(K093)
PhthalIc
Anhydride
Product
01 ST ILLATION
COLUMN
CIIUDE
SIOIIAGE
BOTTOMS
{K0(J4)
Figure 2-2 Schematic Diagram of the Generation of K093 and K094.
(Phthalic Anhydride Production Using Ortho-Xylene as Feed)
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fiD'e 2-Z <.323 - Waste Composition Data
Plart ; Plan: 2
3DAT list :;nst'tjerts
Phthalic iTnyar:ae 67-90 92-99
Ha'ie'C annycr.ae <-0.5
Dfsr :;rist lt.ents
Benzoic 3C0 iC-13 1-6
Reference 13S5
2-7
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of this waste is maleic anhydride. No other BOAT list constituent
{except phthalic anhydride and maleic anhydride) was detected at
treatable concentrations m the untreated waste sample.
2.2.2 K093 and K094 Wastes
All waste characterization data available to the Agency for K093 and
K094 wastes are presented in Tables 2-3 and 2-4. These tables show the
major constituents in the wastes and their approximate concentrations.
The percent concentration of each major constituent in the waste was
determined from best estimates based on chemical analyses and data from
other sources. In K093 and K094, the BDAT list constituent phthalic
anhydride is present in the waste at treatable concentrations. In K093,
the BDAT list constituent maleic anhydride is also typically present at
treatable concentrations. No other BOAT list constituents are expected
to be present in the untreated K093 and K094 wastes at treatable
concentrations.
2.3 Determination of Waste Treatability Group
In cases where EPA believes that constituents present in wastes
represented in different codes can be treated to similar concentrations
by using the same technology, the Agency may combine the waste codes into
one treatability group.
Based on the methods of generation and waste characterization data
available to the Agency for K023, K093, and K.094 wastes, the Agency has
determined that these three wastes represent a single waste treatability
group. These three wastes are generated by the phthalic anhydride
manufacturing industry. They are also generated from similar processes,
2-8
2802g
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"s;:e t-i *.333 - Waste Csnpcsmsn Data
p)dit i 01 ant Z
tx)
SCAT ; -st cor;: itje^ts
Phtha'ic anriyor-cle 10 3S
Maleic anhydr-.de 90 23
Other cons: i tusnt s
Benzoic acid 38
To'.uic ac 'id 1.5
Tg'uic a'dehvce 1.5
Reference: LSEPA ;985
2-9
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Tjo'e :-i *.034 - Waste Csmposit'cn Oata
Plant 1 3 Ian: i
w IS)
BOA''' ' 1 St. const • Uents
Phtha'nc anhydride ¦14 5 50
Other const tuents
Ar.thraqu none 6
Qginones 1.0
Ta-s 54.5 39
Toluic acid 1.5
To
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i.e., during the purification step of phthalic anhydride manufacture.
Although the concentrations of specific constituents will vary from waste
code to waste code, all of the wastes contain similar constituents (i.e..
major constituents present are phthalic anhydride and maleic anhydride)
and are expected to be treatable to similar levels using the same
technology. The Agency has examined the source of these wastes, the
specific similarities in waste composition, applicable and demonstrated
treatment technologies, and attainable treatment performance in order to
support a single regulatory approach proposed for these listed wastes.
2-11
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3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
Section 2 established one treatability group for the management of
KQ23, K093, and K094 wastes. This section identifies the treatment
technologies that are applicable to this treatability group and
determines which, if any, of the applicable technologies can be
considered demonstrated for the purposes of establishing BOAT.
To be applicable, a technology must be theoretically usable to treat
the waste in question or to treat a waste that is similar in terms of the
parameters that affect treatment selection.* 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 available only at
pilot- and bench-scale operations are not considered demonstrated
technologies.
3.1 Applicable Treatment Technologies
Initial data gathering on the treatment of K023, K093, and K094
wastes included review of the technical literature and EPA's National
Survey of Hazardous Waste Treatment, Storage, Disposal, and Recycling
Facilities (1986). ^ .
As shown in Section 2.2, and based on the processes generating K023,
K093, and K094 wastes, these wastes are expected to contain some of the
BDAT list organic constituents and are not expected to contain treatable
levels of BDAT list inorganic constituents. Since K023, KQ93,
For detailed discussions of the technologies that are applicable for
these wastes, or for wastes judged to be similar, refer to EPA's
Treatment Technology Background Document (USEPA 1989a).
3-1
2801g
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and K094 contain BDAT list organics, the Agency considers that 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. Additionally, residuals (wastewaters and
nonwastewaters) generated from the treatment of BOAT list organics should
also be considered for further treatment, if necessary.
The Agency has identified incineration and fuel substitution as
applicable destruction technologies because these technologies have been
shown to treat organic wastes with high Btu content, low metals
concentrations, and low water content. Incineration and fuel
substitution are destruction technologies 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, two
residuals are generated by incineration or fuel suDStitution processes:
ash and scrubber water. The scrubber water from incineration and fuel
substitution is designated as a wastewater form derived from the
treatment of these listed wastes. The scrubber water is not expected to
contain BDAT list organics at treatable levels since most of the organics
are destroyed in the incinerator, furnace, or boiler.
The Agency believes that solvent extraction may be another applicable
technology for K023, K093, and KD94 nonwastewaters. The Agency also
believes that biological treatment, steam stripping, and carbon
adsorption are potentially applicable to wastewater forms of K023, K093,
and K094 wastes.
3-2
ZSOlg
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Based on the waste-generating processes, the Agency does not expect
BDAT list metals to be present in K023, K093, and K094 wastes (both
nonwastewaters and wastewaters); nor is there any reason to believe that
they should be present at treatable levels. Therefore, there is no need
to investigate technologies applicable for treating BDAT list metals.
3.2 Demonstrated Treatment Technologies
The Agency cannot identify any facilities that currently use
incinerators to treat K023 waste. However, incineration is demonstrated
on wastes that are similar to K023 (wastes that have a high Btu content
and a high percentage of organics). Based on the waste characteristics
of K023, the Agency also believes that fuel substitution is demonstrated
on wastes similar to K023 wastes. The Agency lacks data on the current
waste management practices of these phthalate anhydride wastes.
From the information available to the Agency, at least one of the
generators of K093 and K094 uses fuel substitution. Hence, fuel
substitution is demonstrated on K093 and K094 wastes. Since KQ23, KQ93,
and K094 represent a single waste treatability group, fuel substitution
and incineration are demonstrated treatment technologies for Ihe KQ23,
K093, and K094 waste group.
2801 g
3-3
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4. PERFORMANCE DATA BASE
This section presents the data available to EPA on the performance of
demonstrated technologies in treating the listed wastes. These data are
used elsewhere in the document for determining which technologies
represent BOAT (Section 5), for selecting constituents to be regulated
(Section 6), and for developing treatment standards (Section 7).
Eligible data, in addition to full-scale demonstration data, may include
data developed at research 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 as
defined in Section 3.
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 waste
treatability group covered by this background document is 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.
No performance data are available to the Agency to characterize
treatment for K023, KQ93, or K094. However, the Agency has a data base
for incineration of a similar waste, K024, which, as defined by 40 CFR
261.32, is the distillation bottoms from the production of phthalic
anhydride from napthalene. This similarity is based on the production
processes, the waste compositions, and the waste characteristics
4-1
2800g
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affecting performance of the demonstrated treatment technology. The
waste characteristics affecting performance are located in the Treatment
Technology Background Document (USEPA 1989a). The Agency is transferring
performance data from the treatment of K024 to the K023, K093, and K094
wastes since the Agency believes that these wastes are no more difficult
to treat than the tested K024 waste.
The performance data base for K024 waste includes 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 the performance
of the treatment technology.
Tables 3-1 through 3-6 of the Best Demonstrated Available Technology
(BDAT) Background Document for K024 (USEPA 1988a) present the data of
total waste concentration analyses for KQ24 waste samples, as well as the
design and operating data for the treatment system. Based on a review of
the operating data obtained during collection of the samples, the data
sets appear to reflect treatment by a well-operated system. Furthermore,
in all cases the BDAT list organics detected in the untreated waste are
reduced to nearly nondetectable levels in the treated residuals. No BDAT
list metal constituents were detected in the untreated or treated wastes,
nor are they expected to be present.
28009
4-2
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5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
This section presents the Agency's rationale for the determination of
best demonstrated available technology (BOAT) for K023, K093, and K094
nonwastewaters and wastewaters.
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 must first be adjusted for
accuracy, as discussed in EPA's publication Methodology for Developing
Best Demonstrated Available Technology (BDAT) Treatment Standards. (An
accuracy adjustment assesses the ability of an analytical technique to
recover a particular constituent from the waste in a particular test. It
is usually done by spiking a sample with a known a-ount of the target
constituents and then comparing the amount recovered with results from
unspiked samples.) BDAT must be specifically defined for all streams
associated with the management of the listed wastes; this pertains to the
original waste as well as to any residual waste streams created by the
treatment process.
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
determining whether treatment is substantial, EPA may consider data on
2304g
5-1
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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.
Consistent with EPA's methodology for determining BDAT, the Agency
evaluated the incineration performance data for the similar waste. K024,
to determine whether this technology would provide statistically
significant treatment for BDAT list organic constituents in K023, K093,
and K094 wastes. Based on the evaluation of the design and operating
parameters of the similar treatment system, the analytical testing, and
the quality of the data, EPA determined that statistically significant
treatment occurs. This determination is based on the findings that in
all data sets, BDAT list organic constituents are reduced to
nondetectable levels, or to nearly nondetectable l?vels, in the treatment
residuals. In addition to achieving this substantial reduction,
incineration is a widely available commercial technology. EPA concludes
that incineration is therefore the best demonstrated available treatment
for K023, K093, and K094 wastes.
Some commenters on the proposed rule for phthalates pointed out that
phthaiic anhydride can be hydrolyzed to phthalic acid. The commenters
stated that treatment by hydrolysis significantly reduces the toxicity of
the waste (as phthalic acid has significantly lower toxicity than the
phthalic anhydride originally present in the waste). Destruction of
phthalic anhydride by incineration provides a more complete reduction in
28C4g
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total toxicity than simple hydrolysis (i.e., incineration completely
destroys both the phthalic anhydride and the phthalic acid to carbon
dioxide and water, while hydrolysis does not provide any significant
destruction of the organics, but rather enlarges the phthalic anhydride
molecule to the acid form).
As noted in Sections 3 and 4, BOAT list metals are not expected to be
present in K023, K093, and K094 wastes. Hence, residuals from
incineration will not require any treatment for BOAT list metals.
Since incineration for K023, K093, and K094 will generate two
treatment residuals--ash (a nonwastewater form of K023, K093, and K094)
and combustion gas scrubber water {a wastewater form of K023, K093, and
K094)--BDAT must be identified for both types of waste streams.
5.1 Nonwastewaters
As discussed previously, EPA has identified incineration as the best
demonstrated available technology for K023, K093, and K094 wastes as
generated. The Agency believes that fuel substitution is the only other
equivalent demonstrated technology for the treatment of K023, K093, and
K094 nonwastewaters. As noted, incineration/fuel substitution produces
one nonwastewater residual, ash. Since, in all cases, organic
constituent levels in this residual are at or near nondetectable levels
for the tested K024 waste, EPA concludes that no further treatment could
improve upon the levels of performance achieved by incineration or fuel
substitution alone and that no further treatment of the ash for the
organic constituents is necessary. The performance data base for the
tested K024 waste is available in Chapter 3 of the BOAT Background
23C4g
5-3
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Document for K024. Incineration/fuel substitution is therefore the basis
for BDAT for nonwastewater residuals from incineration or fuel
substitution of K023, K093, and K094 nonwastewaters.
5.2 Wastewaters
Scrubber water is the other residual likely to be produced by
incineration or fuel substitution of K023, K093, and KQ94
nonwastewaters. From the treatment data for K024, the Agency expects
that levels of phthalic acid in this wastewater will be below detection
limits. The Agency concludes, therefore, that no further treatment of
this residual wastewater stream could improve upon the level of
performance achieved by incineration/fuel substitution alone and that no
further treatment is required. Consequently, incineration/fuel
substitution is the basis for BDAT for wastewater residuals from
incineration or fuel substitution of K023, K093, and K094 nonwastewaters.
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6. SELECTION OF REGULATED CONSTITUENTS
This section presents the rationale for the selection of regulated
constituents for the treatment of K023, K093, and KQ94 wastes.
Constituents selected for regulation must satisfy the following
criteria:
1. They must be on the BOAT 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 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) for 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 incljde 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 instance, out of a group of constituents that reaot 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 Major Constituents in the Untreated Waste
The analytical data gathered or generated as part of the BDAT program
were reviewed to select major constituents in the untreated waste. As a
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general rule, any BDAT list constituent present in the waste at a
treatable concentration would be eligible for selection.
Phthalic anhydride* and maleic anhydride** are the only BDAT list
constituents detected in the untreated waste. These constituents and
their concentrations identified in the untreated K023, KQ93, and K094
wastes are listed in Tables 2-2, 2-3, and 2-4.
6.2 Constituents Selected for Regulation
Phthalic anhydride is selected as the only regulated constituent for
K023, K093, and K094 because this constituent is present in the untreated
waste at treatable concentrations. Maleic anhydride may also be present
in KQ23 and K093 wastes at treatable concentrations. Since maleic
anhydride is more volatile and has a lower bond dissociation energy than
phthalic anhydride, the Agency believes that maleic anhydride will be
controlled more easily by incineration than phthalic anhydride. Hence,
in the course of achieving any regulatory limit set for phthalic acid
(i.e., the indicator compound for phthalic anhydride), maleic anhydride
will also be adequately controlled. The Agency is using phthalic acid
•»
- »
*Phthalic anhydride is a BDAT list constituent that cannot be easily
analyzed because it rapidly hydrolyzes to phthalic acid in the presence
of moisture. Phthalic acid, although not a BDAT list constituent, is
an indicator for phthalic anhydride. All of the wastewater and
nonwastewater standards for KQ23, KQ93, and K094 are expressed as
"phthalic anhydride ... (measured as phthalic acid)." Thus, the Agency
is specifically requiring analysis for phthalic acid after hydrolysis
of K023, K093, K094, and U190 nonwastewaters.
**Maleic anhydride is being added to the BDAT list of hazardous
constituents.
23C5
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as a surrogate for phthalic anhydride, in phthalate wastes. Although
methods for the measurement of phthalic anhydride concentration exist,
the measurement of phthalic acid concentration as a surrogate for
phthalic anhydride provides a more effective means of measuring
treatment. This is because phthalic anhydride is unstable due to its
hygroscopic nature in the presence of atmospheric moisture. The Agency
has based the treatment standards for phthalic anhydride wastes on the
direct analysis of phthalic acid. The Agency believes that any phthalic
anhydride present in the incinerator ash (if incineration is used for the
treatment of phthalic anhydride wastes) will absorb atmospheric moisture
and hydrolyze itself to phthalic acid. Therefore, analysis for phthalic
acid in incinerator ash is not expected to require a hydrolysis step to
convert phthalic anhydride to phthalic acid. Also, incineration, which
has been selected as BOAT, is expected to destroy Doth phthalic anhydride
and phthalic acid present in the untreated phthalic anhydride waste. The
Agency never intended to analyze solely for phthalic acid in the
untreated waste. In cases where phthalic anhydride wastes have not
p
undergone incineration (i.e., treated residuals of phthalic*anhydride
wastes from treatment technologies other than incineration or the
untreated phthalic anhydride wastes themselves) or in cases where treated
residuals from incineration contain phthalic anhydride that has not been
hydrolyzed to phthalic acid, a hydrolysis step for the measurement of
phthalic acid concentration may be warranted. Currently, there is no
approved EPA method for hydrolyzing phthalic anhydride wastes for the
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measurement of phthalic acid concentration. Until such a method becomes
available, the Agency suggests that hydrolysis for the purpose of
producing phthalic acid for analysis should include the consideration of
the following:
For nonwastewaters containing phthalic anhydride, a representative
sample should be hydrolyzed with a sufficient amount of water (not to
exceed a 10-fold dilution), mixed for a sufficient time to ensure
complete hydrolysis, and then analyzed for phthalic acid. The analytical
results obtained for phthalic acid concentration should then be corrected
to account for the dilution water used to hydrolyze the waste sample.
The Agency reiterates that this hydrolysis procedure is probably not
necessary where BDAT (i.e., incineration) has been employed.
There were no other BDAT list organic constituents (other than
phthalic anhydride and maleic anhydride) detected or suspected to be
present in the untreated K023, K093, and K094 wastes. As noted earlier,
the Agency has no data that suggest the presence of BDAT list metals in
K023, K093, and K094 wastes. Therefore, EPA has chosen not to regulate
BDAT list metals for K023, K093, and K094 at this time.
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7. DEVELOPMENT OF BOAT TREATMENT STANDARDS
The Agency bases treatment standards fc regulated constituents on
the performance of well-designed and well-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 treatment
technology defined as BDAT. Accuracy adjustment of performance data has
been 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 tPA's publication
Methodology for Developing Best Demonstrated Available Technology (BDAT)
Treatment Standards (USEPA 1989b). For details on the calculation of
variability factors for K024 waste, see the Best Demonstrated Available
Technology (BDAT) Background Document for K024 (USEPA 1988a).)
Where EPA has identified BDAT for a particular waste, but because of
data limitations or for some other compelling reason cannot define
specific treatment standards for that waste, the Agency can require the
use of that treatment process as a technology standard. Similarly, where
there are no known generators of a waste or where EPA believes that the
2806g
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waste can be totally recycled or reused as a raw material, the Agency may
specify a "no 1-and disposal" standard, which effectively amounts to
setting the performance standard at zero for all waste constituents.
As noted earlier, treatment performance data for incineration/fuel
substitution of K023, K093, and K094 are not presently available to the
Agency. For K023, K093, and K094 wastewaters and nonwastewaters,
treatment standards have been transferred from incineration of K024
because the Agency determined that:
1. All of these wastes are generated from the production of phthaiic
anhydride.
2. Distillation residues generated from production processes using
napthalene (corresponding to K023 and K024 wastes) are expected to
contain higher concentrations of less volatile constituents than
distillation residues generated from production processes using
ortho-xylene (corresponding to K093 and K094 wastes). Since these
constituents in K023 and K024 have lower volatility, they are more
difficult to vaporize and destroy in a rotary kiln. K023 and K024
are thus more difficult to treat than K093 ind K094.
3. Distillation bottoms (K024) are expected to contain lower
concentrations of volatile constituents than the distillation
light ends (K023) and thus would be more difficult to treat than
K023.
Based on this analysis, the Agency has determined that K024 represents
9
the most difficult to treat of the four wastes generated fr'dm the
production of phthalic anhydride. Consequently, the Agency has no reason
to believe that incineration of K023, K093, and K094 will not perform as
well as incineration of the tested waste, KQ24. The calculation of
treatment standards for K024 is presented in Table 7-1. Table 7-2
presents the treatment standards for K023, K093, and K094 nonwastewaters
and wastewaters, which have been transferred from K024. Where treatment
28Q6g
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performance data are available, the Agency maintains it should establish
concentration-based treatment standards rather than specify a method of
treatment. Concentration-based standards allow industry the flexibility
to use any treatment technology or combination of technologies to treat
the wastes as long as the land disposal residuals produced have
concentrations of the regulated constituents less than or equal to the
treatment standards.
Additionally, the Agency would like to point out that although
methods for the measurement for phthalic anhydride exist, the measurement
of phthalic acid as a surrogate provides a more effective means of
measuring treatment because phthalic anhydride hydrolyzes to phthalic
acid in the presence of atmospheric moisture. All of the wastewater and
nonwastewater standards for K023, K093, and K094 are expressed as
"phthalic anhydride ... (measured as phthalic acid;." Thus, the Agency
is specifically requiring analysis for phthalic acid after hydrolysis of
K023, K093, and K094 nonwastewaters.
26C6g
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2 7 71 g
Table 7-1 Calculation of D0A1 Treatment Standards for K024
Analytical Average Proposed
Concentration accuracy- accuracy- BDAI
in treated correction corrected Variability* treatment
Constituent waste factor concentrations* factor standard
Phthalic acid'*
in nonwastewater
(ash) <8.2 mg/kg 1.19 9.8 mg/kg 2.8 ?8 mg/kg
Phthalic acid'* in
wastewater
(scrubber water) <160 m9/1 1.2 192 nq!I 2.8 0.54 mg/I
'Assures < values are at the detection limit.
Variability factor of 2.8 is used when all samples are below the detection limit for the constituent.
Njscd as an indicator for phthalic anhydride. which n a constituent of K024.
Reference: USEPA 1988a.
-------
?771g
Table 7-2 BOAT Treatment Standards
for K023. K093. and K094
Proposed BOAT
treatment standard
Constituent
total canposition
Phthalic acida in
non»aste*ater
28 mg/kg
Phthalic acid*1 in
wastewater
0.54 ng/1
3Used as an indicator for phthalic anhydride.
7-5
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8. U WASTE CODES
This section addresses the development of treatment standards for
those U wastes designated as phthalates. These wastes include U028
(bis-(2-ethylhexyl) pthalate), U069 (di-n-butyl phthalate), U088 (diethyl
phthalate), U102 (dimethyl phthalate), U107 (di-n-octyl phthalate), and
U190 (phthalic anhydride). The U phthalates have similarities in
chemical structure and elemental content of the primary constituent of
concern (i.e., phthalate) in each waste. Because of these similarities,
these wastes should be treatable to similar concentrations using the same
technology; therefore, the Agency combined these codes into one
treatabi1ity group.
According to 40 CFR 261.33, the above-mentioned 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; and
when they are applied to the land or are contained in products that are
applied to the land.
These materials can be present in different forms, which include:
• 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.
2307g
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8.1 Development of Treatment Standards
Some of the industries that may generate U code phthalate wastes are
industries that manufacture phthalate plasticizers, unsaturated polyester
resins, and alkyd resins, as well as other users of phthalate compounds.
Table 8-1 presents the number of facilities that may generate U028, U069,
U088, U102, U107, and U190 in each EPA Region.
Since these listed compounds are all organics, incineration is
applicable and demonstrated for U phthalate nonwastewaters, as it was for
the K023, KQ24, K093, and K094 phthalate wastes.
BOAT standards for all of these U wastes are being promulgated based
on the transfer of data from the performance of rotary kiln incineration
for K024 nonwastewaters (distillation bottoms from the production of
phthalic anhydride from naphthalene). Treatment standards for K0Z4
wastewaters and nonwastewaters were promulgated wuh the First Third
wastes on August 8, 1988. These standards were based on the performance
of incineration of K024 nonwastewaters in a rotary kiln and the
concentrations of hazardous constituents found in the ash (nonwastewater)
and scrubber water (wastewater) residuals. In today's rule^ the Agency
is setting concentration-based treatment standards for U028, U069, U088,
U102, U107, and U190.
Except for U190 (i.e., phthalic anhydride, which forms phthalic acid
by a hydrolysis reaction), all of these U wastes are esters of phthalic
acid. These esters are commonly referred to as phthalates. The
difference between these compounds is the number of methylene (-CH^-)
hydrocarbon groups on each ester group (e.g., diethyl phthalate has one
2607g
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Table 8-i Nipper cf Fac'l't'es T^t "ay Generate .-C28. -'-69, „ZsS.
J102. J10 7, and U190 in • aci 3egon
E?A Peg 'or Nu^iDer of fac' 1't'es
:x
X
Sefererce: LSEPA 1986
8-3
-------
more methylene on each ester group than dimethyl phthalate). EPA
believes that these structural similarities support the transfer of the
performance data from phthaiic anhydride in K024 to these individual U
phthalates. Standards for these wastes are derived from a direct
transfer of the numerical values for phthaiic acid to each of the
individual phthalate esters (i.e., 28 mg/kg for all nonwastewaters and
0.54 mg/1 for all wastewaters as measured by each phthalate). Currently,
these are the best treatment data on phthalates available to the Agency.
Therefore, the Agency intends to transfer the treatment standards from
phthalic anhydride in K024 wastes to the phthalate esters and phthalic
anhydride U wastes included in the Second Third rule.
Some commenters argued that the Agency has not adequately
demonstrated the transferability of the treatment standards for K024
wastes to these phthalate esters. The commenters ;tated that they had
found no support for EPA's statement that all of these compounds are
anticipated to be easier to burn than phthalic acid. At the same time,
the commenters claimed the following information as support for their
position: (1) the K024 phthalic anhydride residue is a solid and the
phthalates are typically liquids and (2) the autoignition temperature
(a measure of the ease of ignition) for phthalic anhydride is 1Q83°F,
1032°F for dimethyl phthalate, 950°F for phthalic acid, and
735°F for bis-(2-ethylhexyl) phthalate. (Note: The commenters did
not mention an autoignition temperature for diethyl, di-n-butyl, or
di-n-octyl phthalate.)
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The Agency recognizes that many factors affect how easily a compound
can be burned. These factors include boiling point, activation energy,
bond dissociation energy, heat of combustion, heat of formation, and
general structural class. However, the information provided by the
commenters appears to support the Agency's position rather than that of
the commenters. In general, solids should be more difficult to burn than
liquids. In addition, phthalic anhydride with the highest autoignition
temperature appears to be more difficult to burn than phthalic acid or
the other identified phthalates.
Moreover, the data support the Agency's belief that these phthalates
have the same relative difficulty in burning (within the same order of
magnitude). More important, the Agency maintains that the performance
data available to the Agency support its belief that the treatment
standards for the incineration of K024 are not only transferable to these
phthalate wastes but also achievable on a routine basis.
Incineration data for K024 indicate that untreated K024 wastes
contained from 1.3 to 22 percent phthalic anhydride, approximately
10 percent ash, and up to 83 percent polymeric materials. Anajysis of
the incinerator residues for phthalic acid, the surrogate for phthalic
anhydride (see previous discussion for K023, K093, and K094 wastes),
indicated that there was destruction of phthalic acid to detection limits
of 8.2 mg/kg in the ash and 0.16 mg/1 in the scrubber water. Thus, if
phthalic anhydride is, as the commenters' data indicate, one of the more
difficult wastes to burn, then the other phthalates and phthalic acid
28C7g
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should be able to be destroyed to these levels. The Agency points out
that the ash and the polymeric materials present in the untreated K024
wastes also contribute to the difficulty of incinerating this waste.
Thus, the Agency concluded that the K024 wastes are the most difficult to
treat of these wastes.
The commenters expressed concern about several other issues that led
them to believe that the standards could not be achieved. These issues
include the potential for false positives resulting from cross-contami-
nation from: (1) the co-incineration of nonhazardous materials
containing phthalates; (2) plastic materials used during sampling and
analysis; (3) nonhazardous materials co-disposed with treatment
residuals; (4) liners and covers used in roll-off containers used to
transport ash (containing 35 mg/kg of phthalates); and (5) plastic
materials used in the scrubber water systems. The* also argued that
household garbage (containing 22 mg/kg of phthalates) and landfill liners
would exceed the treatment standards. Thus, they concluded that the
treatment standards were not meaningful, nor could they possibly be met.
Several commenters further concluded that since the treatment standards
- ¥
could not be met, the Agency should simply establish incineration as a
technology rather than set concentration-based standards. Finally, one
commenter also stated that the Agency has an insufficient number of data
points upon which to base the standards.
In response to the majority of these comments, the Agency points to
test burn data from four vastly different waste types that illustrate
several of the Agency's positions. The wastes include those identified
Ze07g
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as: (1) KO19 (heavy ends from the distillation of ethylene dichloride in
ethylene dichloride production); (2) K037 (wastewater treatment sludges
from the production of Disulfoton); (3) F024 (various wastes from the
production of chlorinated aliphatics such as distillation residues, heavy
ends, tars, and reactor cleanout wastes); and (4) K.101/K102 (distillation
tar residues from the distillation of aniline-based compounds and residue
from activated carbon in the production of veterinary pharmaceuticals).
These wastes clearly represent a myriad of different hazardous waste
types, and these data are from more than one incineration facility.
EPA analyzed for various phthalates in the incineration residues from
these test burns as follows: (1) six data sets for di-n-butyl and
bis-(2-ethylhexyl) phthalate in K019 ash residues and six data sets for
di-n-octyl, di-n-butyl, and bis-{2-ethylhexyl) phthalate in K019 scrubber
waters; (2) six data sets for bis-(2-ethylhexyl) phthalate in K037 ash
and scrubber wastes; (3) six data sets for diethyl and bis-(2-ethylhexyl)
phthalate in F024 ash and scrubber waters; and (4) six data sets for
bis-(2-ethylhexyl) phthalate in K101 and K102 ash and scrubber waters.
In general, the majority of the measured values for phthalates were
-»
approximately at the detection limit for most of the phthalates
analyzed. In kiln ash, the measured values or detection limits ranged
from <0.42 to <2.0 mg/kg. This is consistent with the estimated
Practical Quantification Limits (PQLs} for these phthalates in ash
residues (as calculated by multiplying the detection limits for the
individual phthalates as measured by SW-846 Method 8250 by the correction
2 8C7 g
8-7
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factor of 670 for low-level contaminated soil) ranging from 1.6 mg/kg for
dimethyl phthalate to a maximum of 2.5 mg/kg for di-n-butyl, di-n-octyl.
and bis-(2-ethylhexyl) phthalate. The data from these four test burns
also indicated that in the scrubber waters the measured values for these
phthalates (or their detection limits) ranged from <0.002 to
<0.050 mg/1. The concentrations of phthalates in the untreated wastes
ranged from 0.05 to 500 mg/kg.
The concentrations of phthalates in the untreated wastes (for the
aforementioned data) were relatively low. Accordingly, EPA did not
attempt to transfer standards for phthalates from these wastes. However,
these data illustrate several important points with regard to cross-
contamination and achievability of the standards. For four different
test burns on four vastly different waste types, analysis of treatment
residuals indicated concentrations or achievable detection limits well
below the promulgated treatment standards (typically an order of magnitude
less). Thus, the commenters' cross-contamination concerns during
incineration, scrubber water processing, sample collection, transport of
analytical samples, and laboratory preparation and analysis of,the
•»
samples are clearly not supported by these data. In addition, the proper
use of analytical techniques in accordance with standard quality
assurance/quality control (QA/QC) procedures in their laboratories can
also reduce the potential for incidental cross-contamination.
With respect to cross-contamination concerns resulting from
incineration of nonhazardous wastes, the Agency notes that, in general, a
facility operator may need to segregate wastes to meet treatment
2307g
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standards, and this need is fully consistent with the intent of the land
disposal restrictions. However, based on the demonstration of
incinerabi1ity of the high concentrations of phthalic anhydride in K024
wastes, the demonstration of achievability of low detection limits for
ash and scrubber waters, and the basic high efficiency of destruction
inherent to hazardous waste incinerators, the Agency believes that
segregation of other wastes from these phthalate wastes is unnecessary
and that compliance with the treatment standards for phthalate wastes
would not be mitigated by co-incineration with other wastes containing
phthalates.
With respect to the cross-contamination concerns stemming from
co-disposal with nonhazardous wastes, from liners and covers of roll-off
containers, or from the landfill liners, the Agency notes that
contamination from these materials (as evidenced i- the commenters' data
referenced above) would be expected to be low compared to the standards.
It appears unlikely that an ash residue that typically contains
<2.0 mg/kg of phthalates would be significantly contaminated to a level
above the treatment standard of 28 mg/kg by wastes containing anly
22 mg/kg or 35 mg/kg of phthalates. The fact that these materials
contain phthalate levels at or near the treatment standards has no
relevance to the achievability of the treatment standards. The fact that
incineration can destroy hazardous wastes to a level that may be deemed
nonhazardous is exactly the goal of incineration.
One commenter suggested that the Agency set technology-based treatment
standards for these wastes instead of concentration-based standards.
This commenter felt that setting technology-based standards would
8-9
ZSC 7g
-------
eliminate the concerns over the achievabi1ity of the treatment standards
because of cross-contamination. Though section 3004(m) specifies that
BOAT treatment standards may be expressed as either concentration-based
levels or as a method of treatment (treatment-based), the Agency
maintains that where treatment performance data are available,
concentration-based treatment standards should be established rather than
specifying a method of treatment. Concentration-based standards allow
industry the flexibility to use any treatment technology or combination
of technologies to treat the wastes as long as the land disposal
residuals produced have concentrations of the regulated constituents less
than or equal to the treatment standards.
Moreover, none of the commenters supported their claims (that the
treatment standards could not be achieved) with data on the measurement
of phthalates in treatment residuals. Because acc-votable treatment
performance data were available for treatment of KC24 and since the data
support the belief that cross-contamination will not affect the
achievabi1ity of the standards, the Agency is promulgating the
concentration-based treatment standards for U028, U069, U088, JJ102, and
U207.
Some commenters on the proposed Second Third rule have also commented
on the difficulty of incinerating contaminated soils with U constituents
because of the low Btu content of soil. The Agency has not yet
determined the transferability of treatment standards to contaminated
soils and debris. The Agency will address this issue at a later date.
2607g
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U190, phthalic anhydride, is not a phthalic ester. Nevertheless, EPA
is promulgating the same BOAT treatment standards as those developed for
K024 based on treatment of phthalic anhydride wastes because phthalic
anhydride, the main hazardous constituent of U190, is the regulated
constituent of K024.
While the promulgated treatment standards for nonwastewaters and
wastewaters for these U phthalate wastes are based on the performance of
incineration of KQ24 in a rotary kiln, other treatment technologies that
can achieve these standards, such as fluidized-bed incineration, fuel
substitution, biodegradation, carbon adsorption, and solvent extraction,
are not precluded from use by this rule. Since the phthalate compounds
consist only of carbon, hydrogen, and oxygen, it is highly likely that
fuel substitution could serve as an alternative to incineration for these
wastes. The Agency is unaware of any alternative treatment or recycling
technologies that have been examined specifically for these wastes.
The U wastes addressed in this treatability group are grouped as
"phthalates" in order to solicit specific comments from manufacturers and
users of phthalates regarding standards for these wastes. In .addition,
analyses for these constituents are often complicated by the high
probability of cross-contamination by these constituents in the
laboratory. Phthalates are common constituents of plastics (such as
plastic gloves used during the analyses) because of their use as
piasticizers. Proper analytical procedures, however, will eliminate or
minimize any cross-contamination.
2607g
8-11
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Tables 8-2 and 8-3 present the treatment standards for the U
phthalate wastes, which are derived from a direct transfer of the
numerical value for phthalic anhydride in K024 to the respective
phthalate compound for the nonwastewater and wastewater residuals. The
Agency believes that the relatively high numerical values (compared to
the treatment levels of phthalates in F024, K019, K037, and K101/K102
wastes) for each individual phthalate will account for the potential
analytical contamination problems (as previously discussed) that are
anticipated from handling wastes that contain these phthalates (i.e., the
U wastes). All standards are based on analysis of total constituent
concentration.
280?g
8-12
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Table 8-2 BOAT Treatment Standards for U Phthalates
U028, U069, UQ88, U102, U107, and U190, Respectively
(Nonwastewaters)
Maximum for any
single grab sample
Total composition TCLP
Constituent {mg/kg) (mg/1)
Bis-(2-ethylhexyl) phthalate
28
Not applicable
Di-n-butyl phthalate
28
Not applicable
Diethyl phthalate
28
Not applicable
Dimethyl phthalate
28
Not applicable
Di-n-octyl phthalate
28
Not applicable
Phthalic anhydride
(measured as phthalic acid)a
28
Not applicable
aUsed as an indicator for phthalic anhydride.
Table 8-3 BDAT Treatment Standards for U Phthalates
U028, U069, U088, U102, U107, and U190, Respectively
(Wastewaters)
Maximum for any
single grab sample
Total composition TCLP
Constituent (mg/kg) (mg/1)
Bis-(2-ethylhexyl) phthalate
0.54
Not, appl icable
Di-n-butyl phthalate
0.54
Hot applicable
Diethyl phthalate
0.54
Not applicable
Dimethyl phthalate
0.54
Not applicable
Di-n-octyl phthalate
0.54
Not applicable
Phthalic anhydride
(measured as phthalic acid)
0.54
Not applicable
2807c
8-13
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9. 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
Association.
SRI. 1988. SRI International. Directory of chemical producers of the
United States of America.
USEPA. 1980. U.S. Environmental Protection Agency. RCRA listing
background document. Waste Codes K023, K093, and K094.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1985. U.S. Environmental Protection Agency. Characterization of
waste streams listed in 40 CFR Section 261 waste profiles. Vols. 1
and II. Prepared by Environ Corporation for Waste Identification
Branch, Characterization and Assessment Division, U.S. Environmental
Protection Agency.
USEPA. 1986. U.S. Environmental Protection Agency, Office of Solid
Waste. Computer printout: Data on phthalate wastes. National
Survey of Hazardous Waste, Treatment, Storage, Disposal, and
Recycling Facilities data base. 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 the land disposal
restrictions program ("BOAT"). Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1988a. U.S. Environmental Protection Agency. Best demonstrated
available technology (BDAT) background document for K024. .Vol. 8,
EPA/530-SW-88-0009-h. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1988b. U.S. Environmental Protection Agency. Final best
demonstrated available technology (BDAT) background document for
K037. EPA/530-SW-88-031I. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1988c. U.S. Environmental Protection Agency. Final best
demonstrated available technology (BDAT) background document for
K016, K018, K019, K020, and K030. EPA/530-SW-88-031B. Washington,
D.C.: U.S. Environmental Protection Agency.
?606g
9-1
-------
USEPA. 1988d. U.S. Environmental Protection Agency. Final best
demonstrated available technology (BOAT) background document for K101
and K102 low arsenic subcategory. EPA/530-SW-88-031K.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1989a. U.S. Environmental Protection Agency. Treatment
technology background document. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1989b. U.S. Environmental Protection Agency. Methodology for
developing best demonstrated available technology (BOAT) treatment
standards. Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1989c. U.S. Environmental Protection Agency. Final best
demonstrated available technology (BOAT) background document for wastes
from the production of chlorinated aliphatic hydrocarbons F024.
Washington, D.C.: U.S. Environmental Protection Agency.
2808g
9-2
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