Frequent Questions

How does a generator correct the constituent values of candidate fuels with a heating value other than 10,000BTU/lb to the 10,000 BTU/lb basis?

To correct the constituent concentrations in the candidate fuel to a 10,000 BTU basis, the generator must determine the appropriate conversion factor. This conversion factor is derived by dividing 10,000 BTU/lb by the heating value of the candidate fuel. To correct constituent values of the candidate fuel, this conversion factor is multiplied by each constituent concentration present in the waste at the point of generation. If none of the corrected constituent values exceed the constituent specification levels in Section 261.38 Table 1, EPA considers the candidate fuel to be comparable to other commercially available fossil fuels. If any of the corrected constituent values exceed the specification limits in Table 1, the candidate fuel is not eligible at the point of generation for the comparable fuels exclusion, since the waste is not similar enough to commercial fossil fuel (63 FR 33782; 33788; June 19, 1998). For example, a candidate liquid F005 listed has a heating value of 5,000 BTU/lb. The waste contains five hazardous constituents at the following levels: 6000 mg/kg total nitrogen, 600 mg/kg total halogens, 60 mg/kg lead, 7500 mg/kg benzene, and 3300 mg/kg phenol. The 5,000 BTU heating value of the candidate fuel must be increased by the factor 2, to be corrected to 10,000 BTU/lb. Thus the constituent values must be corrected by multiplying by 2 as follows: Upon comparing the corrected constituent values of the F005 hazardous waste to the specification levels in Section 261.38 Table 1, the corrected constituent values in the candidate waste for lead, benzene, and phenol exceed the specification levels in Section 261.38. The waste is therefore ineligible for the comparable fuels exclusion. Note that constituents in Section 261.38 Table 1 for which "Non-detect" levels are specified are not corrected for heating value because these constituents may not be present in candidate wastes.

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