Phase IV Article
The final Phase IV Land Disposal Restrictions (LDR) went into effect on August 24, 1998. Two primary provisions of the rule will impact foundries across the country. In most cases, these provisions will translate into increased treatment costs and, for some, the need to completely redesign their waste management process.
| Constituent | TCLP Hazardous Waste Limit (mg/L) |
Final UTS (mg/L) |
| Antimony | NA | 1.15 |
| Arsenic | 5.0 | 5.0 |
| Barium | 100 | 21 |
| Beryllium | NA | 1.22 |
| Cadmium | 1.0 | 0.11 |
| Chromium | 5.0 | 0.60 |
| Lead | 5.0 | .75 |
| Mercury | 0.2 | 0.025 |
| Nickel | NA | 11 |
| Selenium | 1.0 | 5.7 |
| Silver | 5.0 | 0.14 |
| Thallium | NA | 0.20 |
| Vanadium* | NA | 1.6 |
| Zinc* | NA | 4.3 |
| * Vanadium and Zinc are not underlying hazardous constituents. | ||
Stringent Treatment Standards
First, treatment of heavy metals is now required to meet the Universal Treatment Standards (UTS), which are generally more stringent than the hazardous characteristics level (see table).
Iron Dust Treatment Banned
Second, the final rule banned the use of iron dust to treat toxicity characteristic hazardous wastes.
Impacts of the LDRs
How the rule impacts your facility hinges primarily on your waste treatment process. The figure below illustrates the two most common scenarios facing foundries:
Scenario #1: Chemical Addition Prior to the Point of Generation
If you are currently adding chemicals prior to the point of waste generation, it is unlikely that you will be required to meet the new UTS. Regulatory agencies have generally considered these systems to be process modifications—not treatment systems. Foundries in this scenario should:
- Contact an environmental consultant to confirm compliance with the appropriate state agency.
Scenario #2: Chemical Addition After the Point of Generation
If you are currently adding chemicals after the point of waste generation, you will be required to achieve the new UTS. This includes foundries conducting Totally Enclosed Treatment (as defined by 40 CFR260.10) and Treatment in Tanks. Foundries in this scenario should:
- Contact an environmental consultant to determine if treated wastes are below the UTS.
- Consider a cost-effective alternative to current treatment additives and/or redesigning the existing treatment process.
Iron Dust Treatment
The USEPA has banned the use of iron filings as a treatment additive. Foundries currently using iron dust should:
- Contact an environmental consultant to evaluate the design of the existing treatment process.
- Switch to a more permanent and effective stabilization method such as the Enviro-Prep System.
