Document Yj65Lk8vnKjg4DYqoM2NB1k8D

CGnOCOK / Technical Service Report Report No. 34- 80-804-8/839-0 Conoco Jnc. Research and Development Department Corporate Services Section *v Ponca City, Oklahoma ~ To H. J. Neeld, LCCP, Westlake, Louisiana N. From Date Charles A. Bleckmann, Environmental Group, Ponca City, OK Jeffrey Dean Meyers, Environmental Group, Ponca City, OK December 31, 1980 ./ xy Subject An Interim Test Report: Assessment of Lake Charles Chemical Plant (LCCP) and the VCM Plant Wastes for Their RCRA Hazard and Organic Carbon Leachability NOTE: This is an interim report and has been issued to a limited distri bution because the data generated to date is needed immediately. A final report will be issued upon completion of remaining tests. Distribution has been limited to those designated by H. J. Neeld. We strongly suggest that no other copies be generated. The final report will replace this one and receive appropriate distribution. OBJECTIVE 1. Determine if the 42 solid waste samples are hazardous according to RCRA criteria. 2. Determine the leachability of organic carbon from these same wastes. BACKGROUND On May 19, 1980, the U. S. EPA published interim final rules covering identification of hazardous wastes as well as standards for generators, storers, transporters, treaters and disposers of such wastes. These RCRA (Resource Conservation and Recovery Act) guidelines state that for a facility to continue its hazardous waste operations, three requirements must be met: 1. A facility must be defined as "existing;" 2. By August 18, 1980, all facilities handling hazardous wastes must notify the EPA of their wastes and activities pertaining to those wastes; and 3. By November 19, 1980, an application for a RCRA permit must be made. Meeting these requirements will allow a facility to operate under interim final status until a permit is granted or denied. These requirements have been met by the LCCP and the VCM plants. RCRA defines a hazardous waste in general as a "solid" waste (Includes liquids) that may cause substantial hazard to health or the environment when improperly managed. In addition to many specific wastes which the EPA has decided are hazardous and so listed in the May, 1980 publication, wastes which possess certain characteristics are defined as hazardous. Distribution: Gary Foshee, VCM Plant Mike Hayes RMT HHETRLH LIBRARY CCR 000039502 TSR-34-80-804-8/839-0 Page 2 These characteristics are: 1. ignitability - posing a fire hazard during routine management; 2. corrosivity - ability to corrode standard containers or to dissolve toxic components of other wastes; 3. reactivity - tendency to explode under normal management, to react violently when mixed with water, or to generate toxic gases; and 4. EP toxicity - after a prescribed extraction procedure (EP), the pres ence of specified concentrations of certain toxic materials. If a waste has one or more of these characteristics it is considered haz ardous and must be managed accordingly. SUMMARY Evaluation of RCRA hazard was performed on 29 waste samples from the LCCP and 13 from the VCM plant. All appropriate tests have been conducted ex cept for steel corrosion rate on 32 waste samples and ignitability on one. Ten samples -- 6 from the LCCP and 4 from the VCM plants-- must be clas sified as hazardous based on RCRA criteria tested to date. Listed below are these four characteristics of hazard and the number of samples for each plant failing standard tests. RCRA Hazard Characteristic Number of Wastes Railing LCCP VCM Ignitability Corrosion (by pH only)* Reactivity EP Toxicity 64 01 00 00 *Corrosion data is incomplete except for wastes which are completely solid in nature (10 of the 42 wastes samples) and the one waste which has already been found to test corrosive by pH assessment. A pH 5 water extraction of the wastes was performed to quantify leachability of organic compounds as measured by TOC. Ten wastes were found to represent potential leaching problems. Their disposal will have to be managed accord ingly. CONCLUSIONS 1. Final RCRA hazard evaluation has been completed on 10 of the 42 wastes sampled. These wastes and their RCRA hazard test results are: CCR 000039503 TSR-34-80-804-8/839-0 Page 3 LCCP Wastes Charge Gas Dry Mol Sieve Spent F-l A1 Catalyst CDR Sieves Anthracite Filter Ethoxylate Water (Viking) N-Paraffin Drier Sieves Methyl Chloride Carbon VCM Plant Wastes Sample Cor No. Ignitable rosive 13 YES NO 23 NO NO 25 YES NO 27 NO NO 28 NO NO 29 YES NO 31 NO NO Reactive NO NO NO NO NO NO NO EP Toxic NO NO NO NO NO NO NO Copper Chloride Catalyst T-l East Pit Sludge Quench Column Coke 1 5-1 1-80-157 NO YES NO NO NO YES NO NO NO NO NO NO 2. Of the 32 remaining wastes, 6 have been found to be hazardous based on ignitability criteria. These wastes are: LCCF Wastes Holding Pond (Inlet Boxes) Barometric Cooling Tower ` Incinerator Distribution Box VCM Plant Wastes T-2 West Pit Sludge T-500 Pit Sludge Tars Sample No. 6 20 30 5 5-2 12 3. Final RCRA hazard evaluation of the remaining liquid wastes cannot be made until a steel coupon corrosion test is completed. 4. Insufficient sample of LCCP waste #32 (Debutanizer-Depropanizer solids) was available for ignitability and reactivity assessment. 5. Three wastes, when mixed with 16 volumes of distilled water, had a pH of less than 2, These wastes are: a) LCCP Sample #27 (Anthracite Filter) b) LCCP Sample #31 (Methyl Chloride Carbon) c) VCM Plant Sample #12 (Tars) These wastes should be handled as corrosive materials regardless of their RCRA corrosion hazard classification. 000039504 CCR TSR-34-80-804-8/839-0 Page 4 6. Ten wastes contain large amounts of leachable organic material. These are: LCCP VCM Sample #10 Sample #16 Sample #18 Sample #18C Sample #19 Sample #25 Sample #28 Methylene Chloride Acid Neutralization Basin Oil Emulsion Solids Alcohol Emulsion TK553 Alcohol Emulsion TK540 Alcohol Acid Pit-Solids CDR Sieves Ethoxylate Water (Viking) Sample #5 T-2 West Pit Sludge Sample #11 EDC Tar Tank Bottoms Sample #12 Tars 7. The prescribed ignitability test (Pensky-Martens Method) could not be satisfactorily used (waste particle size too large) for three of the wastes. While all three wastes tested "hazardous" using the "Open Cup" method of measuring flash point, there is no doubt that the same con clusion would have been reached using the prescribed method. RECOMMENDATIONS 1, When equipment arrives tests should be conducted to measure corrosivity on steel as prescribed in RCRA regulations. 2. Additional material for LtCP #32 - Debutanizer-Depropanizer Solids should be obtained for ignitability, reactivity and organic carbon leachability assessment. Charles A. Bleckmann Research Botanist Jeffrey Dean Meyers Research Engineer Jlr APPROVED: R. L. Huddleston, Research Group Leader Environmental Group CCR 000039505 TSR-34-80-804-8/839-0 Page 5 INTRODUCTION At your request we sampled 39 solid wastes -- 27 at the LCCP and 12 at the VCM plant -- during the week of October 6-9. Three additional samples (2 from the LCCP and 1 from the VCM Plant) were collected by plant personnel and subsequently submitted to us. All 42 samples were to be tested for their RCRA hazard and organic carbon leachability. This information will aid in choosing proper treatment/disposal methods and provide contractors with required information. As discussed with you before the study began, following EPA procedures for multiple samples, chain of custody and replicate testing would be unneces sary and impractical. However, should you want to exempt a listed waste, further testing would have to be conducted using strict EPA protocol. EXPERIMENTAL METHODS After collection, samples were transported to Ponca City and held at room temperature in the closed sample containers until analyses were begun. RCRA Hazard Evaluation Methods for testing ignitability, corrosivity, reactivity and EP toxicity are referenced in Attachment I -- Analytical Research Section TSR #155-80-839-0/804-8. Organic Carbon Leachability Fifty grams of each waste were thoroughly mixed with 45 grams of distilled water. The resulting mixture was adjusted to pH 5+ 0.2 with either 1.0 N or concentrated HC1. Flasks containing the wastes were then shaken at 200 rpm on a gyratory shaker at 25 C for 24 hours. After 3-4 hours on the shaker the pH was checked and readjusted if necessary. After shaking, cen trifugation was used to separate solids from the liquid. The water frac tions were decanted, filtered through 0.45 pm Millipore filters, and preserved with HNO3 at pH <2.0. These filtrates were analyzed for TOC with an Oceano graphic Carbon Analyzer. RESULTS AND DISCUSSION The results of the RCRA hazard evaluations are summarized in Tables 1 and 2. The analytical results are presented in attached Analytical Research Section TSR #155-80-839-0/804-8. Ignitability A waste with a flash point less than or equal to 140F is classified as hazardous. Because several of the samples were coarse solids, they were run using the "open cup" method rather than the prescribed Pensky-Martens method. Since use of the "open cup" method generally gives higher results than the Pensky-Martens, any samples that tested as hazardous by the "open cup" method would also have been classified as hazardous by the Pensky-Martens test. In sufficient sample was sent for determining the flash point of the LCCP Waste #32 - Debutanizer-Depropanizer Solids. ccr 000039506 TSR-34-80-804-8/839-0 Page 6 Corrosivity RCRA criteria define a corrosive hazardous waste as one that: (1) is aqueous and has a pH 2 or ^12,5 of (2) is a liquid that corrodes steel at il/4 inch per year. Solid samples need not be tested for corrosivity. Only one aqueous sample -- VCM //5-1 - T-l East Pit Sludge failed the pH test. Corrosion tests using steel coupons will be run on the samples as soon as the equipment is available. Until that work is done assessment of the RCRA corrosive hazard for 21 LCCP and 11 VCH Plant liquid samples can not be completed. During the extraction procedure (EP) test, three non-aqueous samples were found to have pH's 2 when mixed with 16 volumes of distilled water. These samples - VCM Waste //12-Tars (organic liquid), LCCP Waste //27-Anthracite Filter (solid), and LCCP Waste //31-Methyl Chloride Carbon (solid) - did not fail the specified pH criterion for corrosivity. However, we suggest that these wastes by handled as corrosive substances to avoid potential adverse environmental or safety problems. Reactivity RCRA reactivity is established by application of specified EPA criteria as listed below. "A solid waste exhibits the characteristic of reactivity if a representa tive sample of the waste bans any of the following properties: 1. It is normally unstable and readily undergoes violent change without detonating. 2. It reacts violently with water. 3. It forms potentially explosive mixtures with water. 4; When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environ ment . v' 5. It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2-and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. 6. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement. 7. It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure. 8. It is a forbidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 CFR 173.53 or a Class B explosive as defined in 49 CFR 173.88. CCR 000039507 TSR-34-80-804-8/839-0 Page 7 For the 42 wastes studied, only criterion #5 was deemed to be potentially relevant. Sulfide was found in 4 LCCP and 2 VCM plant wastes. Cyanide was also detected in one LCCP sample. However, in all cases these two compounds were found to be present in concentrations too low (2 ppm or less) for the wastes to be classified as hazardous due to reactivity. Extraction Procedure (EP)` Toxicity If a waste or waste extract contains any of the following materials at or above the concentration listed, the waste is considered hazardous by RCRA. Arsenic fag/1) 5 Silver (mg/l) 5 Barium Cadmium 100 1 Endrin Lindane 0.02 0.4 Chromium 5 Methoxychlor 10 Lead 5 Toxaphene 0.5 Mercury Selenium 0.2 2,4-D 10 . .1 2,4,5-TP (Silvex) 1 Since it is our understanding that none of the wastes tested contain of the listed pesticides or herbicides, only analyses for the metals were conducted. In no case were any of the specified metal limits exceeded. Organic Carbon Leachability (Not required for RCRA hazard testing) An acidified water leach of the wastes was conducted to provide an esti mate of the amount of organic material that could potentially leach from wastes after disposal, especially landfill disposal. The results of these leach tests are shown in Table 3. Small amounts of organic carbon leached from all samples, but only ten waste leachates contained --700 mg/l TOC and six --3,000 mg/l TOC. One waste proved to contain a large amount of leachable carbon producing a leachate containing more than 10,000 mg/l TOC (LCCP - Waste #28 - Ethoxy late Water). This particular waste was found to be a solid at room temperature but liquid at slightly elevated temperatures. It forms a thick emulsion upon shaking. Other wastes found to possess unusually high leaching potentials were LCCP Wastes #18 and #18C, both alcohol emulsions. CCR 000039508 TABLE 1 SUMMARY OF RCRA HAZARD CHARACTERISTICS _______ FOR LCCP WASTES Sample Humber 1 2 3 4 5 6 7 8 9 10 11 12 13 16 18 18C 19 20 21 22 23 25 26 27 28 29 30 31 32 Sample Designation Waste* Form Ignitability North Lagoon (Sludge) South Lagoon (Sludge) Polishing Pond Digester Pond Storm Water Diversion Basin Holding Pond (Inlet Boxes) Holding Pond (Middle Sect) Normal Paraffin (API Sep) Ethylene/Alcohol (API Sep) Methylene Chloride Acid Neutralization Basin DAF Solids Aluminum Hydroxide Charge Gas Dry Molecular Sieve Oil Emulsion Solids Alcohol Emulsion Tk 553 Alcohol Emulsion Tk 540 Alcohol Acid Pit-Solids Barometric Cooling Tower Ethylene Cooling Tower Alcohol Cooling Tower Spent F-l Alumina Catalyst CDR Sieves Lime from Steam Pit Anthracite Filter Ethoxylate Water (Viking) Normal Paraffin Drier Sieves Incinerator Distribution Box-Head of Polishing Pond Methyl Chloride Carbon Debutanizer-Depropanizer Solids Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Solid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Solid Solid Liquid Solid Solid Solid Liquid Solid Solid OK OK OK OK OK Hazardous OK OK OK OK OK OK Hazardous3 OK OK OK OK Hazardous OK OK OK Hazardous3 OK OK OK Hazardous3 Hazardous OK *2 Corro sivity bv pH OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK6 OK OK OK OK6 OK EP React' Toxiivitv city OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK14 2 3 OK OK5 OK OK OK OK4 OK OK OK OK OK OK OK OK OK OK OK4 OK4 OK OK OK OK OK ,OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK *2 OK 1 "Liquids" were generally sludges and contained large quantities of solids, had no liquid phase. 2 Insufficient sample for analysis. 3 Flash point analysis by "open cup" method. 4 Sulfide detected at low levels. 5 Cyanide detected at low levels. 6 Waste should be treated as corrosive. See text for explanation. 'Solids" CCR 000039509 TABLE 2 SUMMARY OF RCRA HAZARD CHARACTERISTICS FOR VCM PLANT WASTES Sample Number 1 3 4 5 5-1 5-2 6 7 8 9 11 12 1-80-159 Sample Designation Copper Chloride Catalyst T-981 Sludge East T-982 Sludge West T-2 West Pit Sludge T-l East Pit Sludge T-500 Pit Sludge West Equalization Basin Sludge South Equalization Basin Sludge ASU Sludge Bottoms Blosolids ASU Sludge Waste Tank EDC Tar Tank Bottoms Tars Quench Column Coke Waste* Form Ignitability Solid Liquid Liquid Liquid Liquid Liquid Liquid OK OK OK Hazardous Hazardous Hazardous OK Liquid OK Liquid Liquid OK OK Liquid Liquid Solid OK Hazardous OK Corro- sivity by pH EP React Toxi ivity city OK OK OK OK OK OK OK OK OK OK OK OK Hazardous OK OK ' OK OK OK OK OK OK OK OK OK OK OK2 OK OK OK2 OK OK OK OK OK3 OK OK OK OK OK 1 "Liquids"were generally sludges and contained large quantities of no liquid phase 2 Sulfide detected at low levels. 3 Waste should be treated as corrosive. See text for explanation. solids. " Solids" had CCR 000039510 TABLE 3 TOTAL ORGANIC CARBON FOUND IN WASTE LEACHATES (pH5) Sample Number LCCP Chemical Plant Description Leachate TOC (ppm) Sample Number VCM Plant Description Leachate TOC (ppm 1 North Lagoon (Sludge) 2 South Lagoon (Sludge) 3 Polishing Pond 4 Digester Pond 5 Storm Water Diversion Basin 6 Holding Pond (inlet Boxes) 7 Holding Pond (Middle Sect.) 8 Normal Paraffin (API Sep) 9 Ethylene/alcohol (API Sep) 10 Methylene Chloride Acid Neutralization Basin 11 DAF Solids 12 Aluminum Hydroxide 13 Charge Gas Dry Molecular Sieve 16 Oil Emulsion Solids 18 Alcohol Emulsion Tk553 18C Alcohol Emulsion Tk 540 19 Alcohol Acid Pit-Solids 20 Barometric Cooling Tower 21 Ethylene Cooling Tower 22 Alcohol Cooling Tower 23 Spent F-l Alumina Catalyst 25 CDR Sieves 26 Lime From Steam Pit 27 Anthracite Filter 28 Ethoxylate Water (Viking) 29 Normal Paraffin Drier Sieves 30 Incinerator Distribution Box-Head of Polishing Pond 31 Methyl Chloride Carbon 32 Debutanizer-Depropanizer Solids * Insufficient Sample 295 285 255 160 140 180 80 70 125 3,015 35 65 115 3,435 7,630 6,745 3,670 435 75 25 80 700 40 215 >10,000 355 95 .100 * 1 3 4 5 5-1 5-2 6 7 8 9 11 12 1-80-159 Copper Chloride Catalyst T--981 Sludge East T--982 Sludge West T--2 West Pit Sludge T--1 East Pit Sludge T--500 Pit Sludge West Equalization Basin Sludge South Equalization Basin Sludge ASU Sludge Bottoms Biosolids ASU Sludge Waste Tank EDC Tar Tank Bottoms Tars Quench Column Coke - ' 375 50 45 950 380 420 85 115 50 295 2,090 1,180 5 CCR 000039511