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AFS Prevails as EPA Removes RCRA Enforcement Alert from Internet. (Washington Alert).

In a long-awaited move, the U.S. EPA has removed its February 2000 Resource Conservation and Recovery Act (RCRA) enforcement alert, "Foundry Industry's Hazardous Waste Management of Major Concern to U.S. EPA," from the Internet.

Since the early 1990s, the AFS RCRA Working Group has been challenging EPA's policy determinations that:

* shakeout was the "point of generation" for sand waste within the foundry process. If that waste sand exhibited a hazardous characteristic, it would be considered a hazardous waste and fall under the requirements of RCRA Subtitle C;

* thermal reclamation of those "hazardous waste" sands would require the units to be permitted as hazardous waste incinerators.

As directed by the agency, AFS worked to address the industry concerns through EPA's "redefinition of solid waste" initiative between 1995-1999. Unfortunately, EPA could not develop a sound and defendable policy, and the effort was abandoned. Then, in late 1999, the agency identified foundries as potential "RCRA permit evaders" and targeted them for enforcement in FY 2000/2001, even though the policy debate was ongoing.

The AFS RCRA Working Group responded by stepping up its efforts, which proved successful. The point of generation issue was favorably resolved in March 2001 when EPA issued a letter stating that foundry sand reused onsite within the sand loop, including shakeout, is not a solid waste. Only sand that has been removed from the sand loop "for disposal (or for subsequent treatment or storage prior to disposal)" is a solid waste potentially tinder the jurisdiction of the RCRA subtitle C. In addition, sands stored indoors for reuse within the sand loop are excluded from RCRA jurisdiction.

However, the thermal reclamation and related enforcement issues were still ongoing. Since EPA issued the March letter, AFS has been working to persuade the agency to remove the RCRA enforcement alert from the Internet and update it to appropriately reflect the recent policy changes associated with waste management at foundry operations. The agency finally acquiesced.

The AFS RCRA Working Group is still working with EPA toward a resolution on the permitting requirements associated with the use of thermal reclamation within the foundry sand loop. AFS is hopeful that a positive resolution will be forthcoming on the thermal reclamation issue in the near future.
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Comment:AFS Prevails as EPA Removes RCRA Enforcement Alert from Internet. (Washington Alert).
Publication:Modern Casting
Article Type:Brief Article
Geographic Code:1USA
Date:Dec 1, 2001
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