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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 .
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