GCI TECH NOTES ©

Background

Cement kiln dust (CKD) is regulated under the Boiler and Industrial Furnace (BIF) rules. The US Environmental Protection Agency (USEPA) says that CKD could be hazardous because of the waste fuel which is being burned. Thus CKD testing from plants burning hazardous wastes now falls under the waste code of F039. Through this maneuver the USEPA placed CKD under the auspices of the Land Disposal Restrictions of 40 CFR Part 268 and other related Parts. The latest USEPA gambit in this tale is the promulgation of revisions to the standards on September 19, 1994 and further "technically" revised on January 3, 1995 entitled "Land Disposal Restrictions Phase II - Universal Treatment Standards, and Treatment Standards for Organic Toxicity Characteristic Wastes and Newly Listed Wastes".

One of the basic premises of this revision was to standardize the required concentration levels for all of the various organic compounds as listed under the individual waste codes. Interestingly, there are over 200 different organic compounds and metals listed under F039. The regulations state that if CKD is to be placed in a non-hazardous landfill then it cannot exceed the limits as specified for the listed organic compounds. This imposes expensive analysis costs on those cement companies burning waste fuels.

The regulations do state that only those compounds which might reasonably be present, due to the fuel being used, need be tested. Cement companies that have done this evaluation are able to reduce the organic list of compounds to be tested to less then half of the F039 list. This provides a significant reduction in the cost of the on-going test program for CKD.

In addition to standardizing the required concentration levels, the USEPA stated that changes were made in the levels to better match the laboratory detection levels. The first numerical column in the attached table was the original F039 limits as published in June, 1990 and made applicable to CKD in November, 1993. The second numerical column provides the limits as they now exist as a result of the latest changes. It behooves all concerned to review any pertinent data against the new limits. If the limits are at or near the detection limits in the laboratory then it is possible that old data no longer proves compliance. It is also interesting to review the absolute change and the percentage change. Many of the changes are relatively small, but there are a few where the change is quite large. There was no apparent explanation for these large changes. For example, toluene was reduced from 28 ppm limit to 10 ppm, a reduction of 18 ppm or 64%. This needs to be watched carefully since toluene has been found at these levels in CKD whether waste fuel was used or not. Benzene is another organic compound to watch where the limit went from 36 ppm to 10, a 72% reduction. A review of the included table shows a reasonably large number of serious reductions in the limits. Strangely, there are a few very large increases in the limits, such as butyl benzyl phthalate.