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Foundry waste research: a model for industry.

Environmental Information, Ltd. Minneapolis, Minnesota

Few people in waste management would argue that as time proceeds, state and federal environmental agencies will set increasingly stringent management requirements for a growing number of industrial wastes. Industry must take responsibility for thoroughly understanding its own wastes to work intelligently with the regulatory agencies in developing a waste management policy.

This will help ensure that waste management funds are spent wisely to provide the greatest protection while avoiding regulation that increases cost without providing additional benefits. While this may be an obvious point, thorough waste research efforts by industry are still not the norm, according to David Friedman, chief of the Off ice of Solid Waste Methods Section in the U.S. Environmental Protection Agency (EPA).

Foundries, however, constitute one industry group that has developed and maintained an extensive waste management research effort since the early 1970s. Their research has not only earned the praise of EPA officials, but has also resulted in a series of important EPA decisions that have saved the industry many millions of dollars in waste disposal costs.


When 1970 arrived, along with the first Earth Day and the development of the EPA, the foundry industry recognized that tighter regulations for industrial waste management would soon follow. The industry, which then claimed about 4400 members, had good reason to be concerned. Foundries were generating about 400 million tons of waste each year, according to Walter Kiplinger, vice president of government affairs for the American Cast Metals Association (now the American Foundrymen's Society). Any change in regulations had a tremendous potential for causing a significant economic burden.

Industry members determined that they would begin to characterize their waste and how it behaved in the environment. This initiative was certainly innovative during the early 1970s, but in a way it was a logical extension of foundry efforts that dated back to the mid-1930s.

"The American Foundrymen's Society has had a full-time environmental staff person since 1935," said William Huelsen, retired vice president of environmental affairs for AFS.

"The thing that has been impressive about the AFS work," said Thomas Kunes, CEO of RMT, a Wisconsin-based consulting firm, "is that it has always been looking ahead, being proactive and not reactive. These people were real leaders because they asked what are the environmental waste disposal issues we will face and how will we go about solving them."

"In 1970, the AFS Water Quality and Waste Committee could foresee that controls would have to be put on some wastes to close the environmental loop, that is, to prevent them from getting into the environment," Huelsen said. Industry members, however, did not know what was in their wastes beyond the raw materials that went into the process.

AFS contracted with the University of Wisconsin-Madison to conduct a materials balance on the wastes from a number of foundries to find out what was going into the process and what was coming out as waste. The work was led by professors Robert Ham and William Boyle.

Involving Ham and Boyle in the early days paid dividends for many years as the two professors subsequently developed innovative and meaningful research that formed the infrastructure of the foundry waste information base. AFS decided on the University of Wisconsin because its civil engineering department already had conducted research on waste and AFS "didn't want to pay for somebody's learning curve," Huelsen said.

Following the materials balance research, AFS commissioned the university to develop a procedure by which it could evaluate the leachate produced by storm water falling on the wastes. The researchers developed a leaching procedure in which wastes were placed in a flask and the flask was filled with distilled water. The flask was shook for a specified period and the liquid was then tested for contaminants.

This leaching procedure, now referred to as the AFS leaching test, "is believed to be the first published test developed to examine the leaching characteristics of a specific waste," according to an article by Ham and Boyle in the February 1990 issue of modem casting. The researchers then used the leaching test to evaluate various foundry wastes and found that three factors had a large impact on waste characteristics:

* raw materials;

* particle size (the larger the particle

size, the lower the leached quantities);

* temperature (less organic material

leached if the waste had been subjected

to high temperature).

In the second phase of the research initiative, researchers tested laboratory scale landfills that measured 2 x 2 x 1.5 ft deep. They used a special simulation apparatus to subject the test scale landfills to weather conditions that matched those of Jackson, Michigan. The city's environment was considered typical of locations where foundries operate. The weather simulator could replicate a year's worth of weather in only four months.

Ham and Boyle found that "foundry processes produced wastes with widely different leaching characteristics. Therefore, it was not possible to classify all foundry process wastes as representing equal threats to groundwater quality." This would soon prove to be a valuable finding.

To List or Not To List

On August 22, 1979 the EPA published a proposed list of hazardous wastes that included lead/phenolic sandcasting waste from malleable iron foundries. Since the proposed listing took it by surprise, industry asked the EPA for the data supporting the decision.

"Between August 23, 1979 and September 6, 1979, we made repeated phone calls to EPA, and on September 6 we mailed a formal letter requesting the data," Kiplinger said. On September 12, the Cast Metals Federation and AFS requested a 90-day extension on the comment period, which was scheduled to end on October 12. On October 12, the agency extended the comment period by 45 days because the data was not available.

On November 1, the EPA said the data was still not available, and wouldn't be until after November 26, the date the comment period was set to expire. ACMA and AFS requested that the comment period be extended 90 days after the data became available. On November 26, phenol was deleted, but gray iron foundry treatment sludges were still included in the listing, according to Kiplinger.

"To make a long story short, this kind of thing continued well into 1980 before we finally received the support data," Kiplinger said. When the foundry members finally had the data, they were well equipped with their own information and "punched holes in the EPA's data."

AFS and ACMA were able to show that the EPA had never conducted the tests that would justify listing lead-bearing treatment sludges as a hazardous waste. "They had never done the leaching procedure that they themselves consider necessary to show toxicity," Kiplinger said.

The EPA then began a major study to determine the legitimate listing of foundry sludge. it studied elements such as specific furnace types, furnace linings, scrubbers and feed stock. Kiplinger said one of the major results of the studies was that the EPA became very knowledgeable about the foundry industry.

"People often confuse us with the steel industry because we both melt metal," Kiplinger said. But while the steel industry produces essentially only steel in 32 shapes, the foundry industry produces more than 20 alloys, uses eight furnace types and produces several thousand shapes. "We sent Bill Huelsen to talk with David Friedman because Bill knows more about foundry processes than any person alive," Kiplinger said.

Huelsen presented AFS studies to show that "there was enough variability in the foundry waste to show it was not `usually and frequently hazardous,' which is the criteria for listing a waste as hazardous," Friedman said. Ultimately, the treatment sludge was removed from the listing and foundries were able to follow the characteristic requirements.

From the beginning of the research process in 1970, the foundry industry maintained an ongoing dialogue with the EPA. AFS supplied the EPA with copies of all its findings and informed the agency of its current research projects. industry members point to this communication as a primary reason they have been successful at influencing waste management policy. The Research Continued

The research effort did not stop, however, after the foundry wastes had been removed from the proposed list of hazardous wastes. AFS continued to fund studies to better understand how foundry wastes behaved in the environment. The next step was to move the research into the field and study existing foundry waste landfills. The research in this third phase was conducted by the University of Wisconsin and RMT.

Efforts were headed by Kunes, who as a graduate student had worked with Ham and Boyle in developing the leach tests. Kunes was one of several graduate students who benefited from the AFS funding that helped greatly in developing the waste management program at the University of Wisconsin. Several students, including Thomas Liu and Peter Kmet, went through the program and eventually had an impact on waste management.

University of Wisconsin researchers studied six landfills and existing leachate data from a seventh. Researchers installed pressure/vacuum lysimeters in the unsaturated zone of six landfills. They leached the auger samples to determine how the leachate might vary among different wastes in various areas of the landfill. They also collected leachate samples in the lysimeters and analyzed them. This allowed them to compare the laboratory results to field conditions. The RMT researcher studied waste samples and groundwater from seven additional ferrous foundry landfills.

The combined research efforts made the following key findings:

*Leachate from the unsaturated zone

had relatively low concentrations of

contaminants except iron and manganese,

which exceeded drinking

water standards in all landfills, and

fluoride, which exceeded drinking

water standards in three landfills.

*The variability of foundry wastes and

landfills affected leachate quality. Also,

leach tests on auger samples of waste

were more accurate in predicting

leachate quality than were raw

samples of waste.

*The RMT studies indicated that no

landfills contributed amounts greater

than the drinking water standards for

arsenic, cadmium, chromium, lead,

mercury, selenium or silver.

*The melting furnace emission control

waste tested EP toxic in three foundries,

but at none of their landfills did

the leachate contain the metals in the

groundwater at the disposal cell

boundary or from water within the


The Single Liner Requirement

As this study was progressing, another waste management issue arose in which the foundry industry requested the EPA to study its wastes to determine if foundry waste landfills could be allowed to have a single liner even if the wastes exhibited toxicity under the EP standard.

Industry first proposed the single liner requirement just as the Resource Conservation and Recovery Act (RCRA) was coming up for reauthorization during the mid-1980s. The industry wanted the provision written into the new RCRA legislation. The EPA responded that it did not have adequate resources for studying the issue.

Recognizing that the EPA had legitimate budget constraints, the AFS approached U.S. Rep. Bob Traxler (D-Michigan) for assistance. AFS chose Traxler for two key reasons: His state and district had several foundries and he was on the Ways and Means Committee.

"Traxler was very upfront with us on this issue," Huelsen said. "He reviewed our findings with us and said that he would help EPA get the money if we weren't hiding anything." Traxler apparently was convinced of AFS' openness and the legitimacy of its findings because the agency ultimately received the money to conduct the studies.

The EPA conducted several studies, further characterizing the wastes and how they performed in the environment. With each sample it collected, the EPA sent half to the laboratory conducting the test and half to the University of Wisconsin for the same analysis. This verified the EPA's data and the AFS test procedures.

"At that time, the thrust in the agency was to prevent cancer in the general population," said Gary Mosher, director of environmental affairs for AFS. The data showed that the contaminants leaching from foundry wastes did not pose a cancer risk.

Industry contended that the double liner requirement would cause a great deal of financial burden to the industry with negligible gain in health benefits. "We asked the agency, `How can you justify this great expense to our industry without a resulting benefits?" Mosher said. Ultimately, the foundry industry was awarded another enviable decision when the "Traxler Amendment" (as it became known) was included in the legislation and subsequently the regulations. The regulation reads in part:

"264.301 and 265.301

(e)The double liner requirement ... may be waived ... if:

(1) The monofill contains only hazardous wastes from foundry furnace emission controls or metal-casting molding sand, and such wastes do not contain constituents which would render the wastes hazardous for reasons other than the Toxicity Characteristic in S261.24 of this chapter, with EPA Hazardous Waste Numbers D004 through D017..."

Results with the State Agencies

Working with the states in developing waste management regulations has been a third important result of the research, according to industry members.

"During the early to mid-1980s, states were developing their own regulations for industrial wastes," Mosher said. "States with big foundry industries knew a fair amount about foundries, but other states did not. We filled the information vacuum about our wastes and eased the fear of the unknown."

The Third Third

The proposed rule for the third third of the land disposal restrictions presented another challenge to the foundry industry. The proposal included provisions that would have required the treatment of foundry wastes such that the BDAT levels for lead would have been one-tenth, and for cadmium one-fifth, that which would render the waste hazardous by the characteristic standard.

"What we found in dealing with the EPA on this issue was that there had been so much change at the agency since the early 1980s that the EPA was again working in a knowledge vacuum about the foundry industry. We had to get back into the education mode," Mosher said.

Because the case for economic burden did not have sway in this argument, the industry showed there was inadequate capacity to manage the waste before the May 8 deadline, and that the volume estimates were way off. AFS was again able to show that the contractor making the recommendations had made "massive extrapolations from a couple of studies," Mosher said.

Eventually the EPA changed its entire position on the issue of treating wastes to below characteristic levels and extended the compliance deadline to August 8. Since these changes applied to many wastes in the third third, it is difficult to determine the degree of impact the foundry studies had on the decision. However, one can safely assume that the lobbying effort by the foundry industry played a role in persuading the EPA.

Lessons To Be Learned

The people involved in the research effort, which has now spanned nearly 20 years, emphasize that they see the keys to their success as a combination of factors:

* good research technique and data;

* openness and a willingness to share

all information;

* consistency and credibility in communication


"There have been a lot of letters and consistency in our message," Kunes said. "The AFS and Cast Metals Federation became recognized as responsible spokespersons for the industry, and AFS had been very careful and deliberate in sharing the reports on their research efforts. I don't think the dialogue would have happened if that credibility had not been established."

The value of this somewhat commonsense approach is verified by the EPA's Friedman. "In general," he said, "given the limited resources and manpower the agency has to study things, the way you are going to convince us is with good data. if you think our limited study is not going to give the answer that you think is correct, then work with us in a straightforward and open manner. We will see what the numbers say.

Friedman acknowledges that the number of industry groups conducting thorough waste analysis has increased as various hammers in the land ban have passed. "It's the best way," he said, "but it still is not very common."

Foundry industry members also believe there has not been much cross-industry transfer of waste research approach.

"The foundry approach could very well serve as a model for how other industries could approach the issue," Kunes said. "This has been a wonderful string of projects to be involved in."

This article was originally published in the September 1990 issue of "Environmental Information, Ltd., " an industrial and hazardous waste publication, and is reprinted here with permission.
COPYRIGHT 1991 American Foundry Society, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1991, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

Article Details
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Title Annotation:Focus on the Environment
Author:Smith, Jeffrey D.
Publication:Modern Casting
Article Type:Cover Story
Date:Feb 1, 1991
Previous Article:Illinois Technology grants to fund heat treatment and vacuum casting projects.
Next Article:What to expect from the new Clean Air Act.

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