United States Environmental Protection Agency             
Solid Waste and Emergency Response (5305W) 
Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009)
EPA530-F-00-021
July 2000             


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 of
K088 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.   


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/[date of
publication].  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.