|Gossman Consulting, Inc.|
GCI TECH NOTES©
Cement Kiln Dust Testing for Organics
Cement kiln dust that is wasted from a cement kiln which uses hazardous waste as a fuel source must meet the regulatory requirements laid out in 40CFR 266.112 which addresses the regulation of residues from boilers and industrial furnaces. Specifically, the wasted CKD must be sampled and analyzed as often as necessary to determine whether the residue generated during each 24-hour period has concentrations of toxic constituents that are higher than the health based levels. A comparison of waste- derived residue with normal residue may be performed instead. But given that the health based approach is taken, the non-metal constituents must comply with levels defined as the land disposal restriction limits specified in 268.43 [a 22 word section which refers back to 268.40]...for F039 nonwastewaters.
Does this mean that checking for any and all compounds listed under F039 in 268.40 is necessary? This is certainly one way to approach the requirement, and the most conservative for sure; but then, analyzing for unnecessary organics occurs and will likely significantly increase analytical costs.
Another way is to identify Appendix VIII, part 261 constituents (toxic constituents) that could reasonably be attributable to the hazardous waste as per 266.112. The most readily defensible way to accomplish this, and maybe the only regulatorily defensible way, is by using the waste codes listed on the facility Part A. This waste code list can then be broken down into the associated organics found in 261.31, 261.32, 261.33 & 261 Appendix VII. This list of organics can then be compared to the list of organics provided for F039 in 268.40. All organics found on both lists would then fit the 266.112 requirements of Appendix VIII, part 261 constituents reasonably attributable to hazardous waste and land disposal restriction limits...for F039 nonwastewaters. However, one issue of significant concern is the matching of specific organics listed in F039 with general or group listings found in 261 appendix VIII. Group or general listings such as chlorinated ethanes or chlorinated fluorocarbons open up, for inclusion, numerous organics specifically listed under F039. A recent comparison performed by Gossman Consulting, Inc. resulted in the consideration of 33 additional compounds for CKD organic analysis, due to the group listings in 261 appendix VIII, of which thirteen compounds were added to the CKD analysis.
Another issue of concern, no matter how you determine the appropriate CKD organics, is the actual list of organics found in 268.40 F039. This list is regularly modified as was the case in late 1994/early 1995 (see April 1995 GCI Tech Notes), April 1996 and again in February 1997. Each of these modifications included changes which potentially impacted the list of CKD organics for which to analyze. It is all too easy to be lulled into an unwarranted sense of security over CKD analysis. If you are sure of your list of CKD organics and have proper documentation, then you can withstand any sudden intensified scrutiny by the EPA. Take it from a consulting firm that faced the intense glare of a Regional enforcement action, frantically scrambled through documentation and analytical records, ultimately to demonstrate that it was in fact the EPA that had not done their homework. This was not fun. In fact, it was intensely nerve racking. It s great to emerge victorious, when all is said and done, but the only way to help insure that outcome is to have your ducks in a row before you are pulled into battle. For your own ultimate peace of mind, double-check those CKD organics today!