Phase IV of the Land Disposal Restrictions (LDR)
On May 26, 1998, EPA promulgated final regulations concerning Phase IV of the LDR under RCRA. These new regulations require generators of hazardous metal-bearing wastes, and wastes derived from metal processing (some of which were previously covered under the "Bevill Amendment") to be treated prior to land disposal. The new treatment standards, which are called the Universal Treatment Standards (UTS) are, in most cases, a fraction of the toxicity characteristic hazardous waste criteria. EPA also required that generators treat their hazardous wastes for "underlying hazardous constituents" in addition to the hazardous constituents that made the waste a hazardous waste in the first place. Thus, a waste that may have exhibited the toxicity characteristic for lead would have to also achieve the UTS for any other underlying hazardous constituent that could reasonably be expected to be present in the waste. On a somewhat separate issue, EPA declared that the use of iron dust to treat heavy metal–bearing wastes (often employed by brass foundries to treat hazardous foundry sand) was "impermissible dilution." The impact of this new rule will be higher testing costs (characterization and treatment effectiveness), additional treatability testing, and potentially higher treatment costs.
OSHA Rulemaking for Crystalline Silica
On October 31, 1996, the U.S. Department of Labor launched a national public education campaign to prevent silicosis. OSHA, a branch of the Labor Department, joined the effort and initiated a Special Emphasis Program (SEP) to reduce worker exposure to crystalline silica. Now, OSHA is in the early stages of developing a new, stricter standard for silica which could have significant economic impacts on foundries. Although the rule is not likely to be finalized until 2002, foundry industry efforts for involvement in the rulemaking process have already begun.
Increasing Emphasis on VOC Control
Foundries are now widely recognized as significant sources of VOCs from mold- and core-making, pouring, cooling and shakeout operations. Existing air pollution permitting and control regulations at the state and federal levels are increasingly applied to foundries and new, stricter regulations are likely.
New Emission Factors
There are many efforts under way to develop more accurate emission factors for foundry processes. In addition to literature reviews, both the USEPA and CERP are developing better data through testing in foundries. This new data will likely indicate that foundry emissions, particularly for VOCs and HAPs are currently being significantly underestimated. The use of these new, more accurate emission factors could result in many foundry processes being subject to additional permitting and/or control requirements.
Beneficial Reuse of Process Wastes
There have been numerous state initiatives to develop regulations that facilitate the reuse of process wastes generated by the metals industry (i.e., sand, slag, etc.). These initiatives, if properly constructed, have given individual facilities waste management options other than land disposal for these materials. Often, these options are less costly than waste disposal. Further work is needed to ensure that these programs are continued and are improved to facilitate even more reuse options so as to reduce waste management costs while still protecting the environment and minimizing generator liability.
Clean Water Act
The Clean Water Act regulates the amount of chemicals/toxics released by industries via direct and indirect wastewater discharges. The following effluent guidelines and standards are applicable to activities performed during foundry/metal forming and finishing operations:
- Iron and Steel Manufacturing (40 CFR Part 420)
- Metal Molding and Casting (40 CFR Part 464)
- Aluminum Forming (40 CFR Part 467)
- Copper Forming (40 CFR Part 468)
- Nonferrous Forming (40 CFR Part 471)
- Lead-Tin-Bismuth Forming (40 CFR Part 471)
- Zinc Forming Subcategory (40 CFR Part 471)
- Electroplating (40 CFR Part 413)
- Metal Finishing (40 CFR Part 433)
- Coil Coating (40 CFR Part 465)
The EPA is currently developing effluent guidelines and standards for the metal products and machinery industry. The development of guidelines for the metal products and machinery industry, and revisions to the existing standards, are based on a biennial schedule published by the EPA. In addition, EPA is emphasizing enforcement of "in-stream" water quality which may have an impact on storm water discharges from the metals industry.
