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EPA publishes new land ban regulations, (Environmental Protection Agency)

EPA Publishes New Land Ban Regulations

On Nov 22, 1989, the Environmental Protection Agency (EPA) published a Proposed Rule on the "Land Disposal Restrictions for Third Scheduled Wastes" (Federal Register, vol 54, No. 224, pp 48372-48529). This proposal is in direct response to the Hazardous and Solid Waste Amendments (HSWA) of 1984, which, in essence, banned the land disposal of untreated hazardous waste after May 8, 1990.

In the HSWA, Congress directed EPA to promulgate treatment standards for listed hazardous wastes on a schedule of one-third of the list by Aug 8, 1988, two-thirds by June 8, 1989 and the third one-third by May 8, 1990. The November 22 proposal completes this schedule with the third one-third list including wastes that are classified hazardous due to a characteristic, i.e., EP toxicity, reactivity, etc. If a foundry waste is classified as hazardous, it is usually because of a characteristic such as EP toxic lead.

These rules apply to materials that are classified as hazardous waste either through a specific listing, i.e., K061 electric Arc Furnace dust from the primary production of steel, or because they exhibit a hazardous characteristic, i.e., EP toxicity.

Treatment Standard vs. Method

For some wastes, EPA has established treatment standards, which are the maximum concentrations that may leach from a treated waste. These standards are written as performance standards. EPA does identify some generic technology, i.e., precipitation using lime, carbonates or sulfides, but leaves it up to the generator/treater to determine the specific technology to be used to meet the standard. This was done to allow flexibility in how to comply with the rule.

The treatment standards themselves were set based on an EPA review of the Best Demonstrated Available Technology (BDAT) for a particular waste. Sources of this technology included treatments identified in Effluent (waste-water) Limitation Guidelines, or those which were identified for similar wastes in earlier submissions on the first or second one-third scheduled wastes. The latter source was used extensively to determine BDAT for metals.

For other wastes, EPA has identified treatment methods that must be used on those wastes. In this case, there are no concentration limits. When the treatment method is used, i.e., thermal recovery of lead for wastes that contain greater than 2.5% lead by weight, by definition, the waste is no longer hazardous. The residue from the treatment method though, may still have to meet treatment standards. Table 1 lists the treatment standards/methods for chemicals that may cause a foundry waste to be classified as hazardous.

Wastewater vs. Nonwastewater

EPA has broken hazardous waste into two broad categories: wastewater and nonwastewater. Wastewaters are defined as "those wastes (listed wastes, including wastes generated as a result of the 'mixture' and 'derive-from' rules) that contain less than 1% total organic carbon (TOC) and less than 1% total suspended solids ...

Those wastes (listed wastes, including wastes that are hazardous as a result of the 'mixture' and 'derived-from' rules) that do not meet these criteria are defined as nonwastewaters ..."

From a foundry's standpoint then, more than likely any waste that may be classified as a hazardous waste due to a characteristic is probably a nonwastewater waste.

Dilution Prohibited

EPA is expressly prohibiting the dilution of a hazardous waste with a nonhazardous waste as a method of treating the hazardous waste to below the treatment standard. They do identify situations where such mixing is allowed provided there is a demonstrable reduction in either toxicity or mobility of the hazardous constituent.

As a result, the practice of mixing a waste, for example baghouse dust, which is EP toxic for lead, with spent molding sand, is no longer allowed. If such mixing continues after May 8, 1990, the entire mixture will be treated as a hazardous waste with the appropriate treatment standard or method being applied. In other words, bad plus good equals bad.

Testing Requirements

To determine compliance with the treatment standards, EPA is requiring a new testing method. For "wastewater" wastes, the total concentration of the particular hazardous ingredient must be determined using an approved EPA method. For "nonwastewater" wastes, the material must be tested using the Toxicity Characteristic Leaching Procedure (TCLP).

The TCLP is an entirely different procedure than the Extraction Procedure (EP) used in the past. There is no frequency of testing requirements for generators, but treaters will be required to test the treated waste annually. Since there are no established correlations between EP results and TCLP results, foundies which are testing their waste using the EP should retest using the TCLP. Treatment facilities will most likely require generators to test using TCLP.

Calcium Carbide in Slag

For wastes that are waste reactive, e.g., calcium carbide in slag, EPA has proposed deactivation as the treatment method. Foundries that deactivate this waste on site probably will have to obtain a treatment permit.

For wastes that contain reactive sulfides, EPA is setting treatment standards of either alkaline chlorination, chemical oxidation or incineration. These steps are then followed by precipitation to insoluble sulfates.

Capacity Determination

Though Congress set a deadline of May 8, 1990, for the land ban to go into effect, EPA was given the authority to extend it by up to two years if they determined that there was inadequate capacity available for the volume of waste to be treated. For most hazardous wastes of interest to foundries, EPA has determined that there is sufficient capacity and has reaffirmed the May 8, 1990 deadline.

Other Issues

Phenol is a chemical regulated under this proposal. It us unclear at this time whether foundry waste that contains greater than 6.2 mg/kg phenol will have to be treated. If so, these wastes may have to be incinerated or go through some type of biological treatment.

EPA can grant variances from the treatment methods and standards. To obtain one, a company must contact EPA and provide detalied information on why a variance should be granted.

The generator of a hazardous waste that does not meet the applicable treatment standards must, with each shipment of waste, notify the treatment facility in writing of the appropriate treatment standards. This notice must include the EPA hazardous Waste Number, the corresponding treatment standards and all applicable prohibitions, the Manifest number associated with the shipment of waste and waste analysis data where availiable.

Waste produced by small quantity generators of less than 100 kilograms of hazardous waste (or less than one kilogram of acutely hazardous waste) per calendar month are conditionally exempt from RCRA, including the land disposal restrictions.
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Author:Mosher, Gary E.
Publication:Modern Casting
Date:Jan 1, 1990
Words:1087
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