oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9486.oi(8i)
TITLE: Hazardous Waste Regulation of Gray Iron Foundry
Waste
APPROVAL DATE: e-is-si
EFFECTIVE DATE: e-ia-si
ORIGINATING OFFICE: office of solid waste
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Q DRAFT
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OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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..PARTS 264 AND 265 SUBPART M - LAND TREATMENT
DOC: 9486.01(81)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Iron Foundry Waste, Treatment
40 CFR Parts 261, 264
Hazardous Waste Regulation of Gray Iron Foundry Waste
Gary Perket, Environmental Engineering & Management Ltd.
David Friedman, Manager, Waste Analysis Program, Hazardous
and Industrial Waste Division
#9486.01(81)
6-18-81
Testing of the residue for hazardousness prior to the mixing of the cupola
and sands in a disposal site would require that the testing be done separately
from the waste sand. If the mixed waste entering the disposal is not hazardous
but the cupola is, the combined waste is no longer hazardous and the plant
would only require a treatment permit. Part 264 standards have to be met by
the facility in order to obtain a permit.
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9486.01 (81)
UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
WASHINGTON. D.C. 2046C
CFFICZ Or SCLID
J* I
OFFICE OF WATER
AND WASTE MANAGEMENT
Mr. Gary Perket
Environmental Engineering « Management, Ltd.
Suite 400
7400 Metro Blvd.,
Minneapolis, MN 55435 •
Dear Mr. Perket:
I am writing in response to your March 9, 1981 letter to Mr, Jack Lehman
asking for clarification of the hazardous waste regulations with respect to gray
iron foundry waste.
Your first question, is it acceptable to test the combined sands and cupola
drcc as a singl* waste stream oresents us with a problem. In the example cited,
you' indicate that the hazardous waste cupola material never really appears outside
of a closed svstem except in admixture with the sand. Thus, one might think that
the sanJ-cuooia drco combination should be tested as one waste. However, in
reality things may not be so easy. First, I am not sure that the sand and cupola
residue actually become intimately mixed during the dropping operation. If I
correctly understand the process you described, the sand just forms a base,
similar to a charcoal grill firebase, for the cupola residue. Thus, -the cupola
residue actually does not become mixed with the sand unless and until it is
mixed in the disposal site. If my -understanding is correct, then the cupola
-esidue should be .evaluated separate from the waste sand ir one is trying to _
determine if either is hazardous. Also, the six afferent sources or waste sane
would also have to be evaluated separately.
If the cupola dust is found to be a hazardous waste, but the mixed waste
ent-ring the disposal site is not, then the plant would only require a treatment
SSlinS oncTthe wastes are mixed together they cease to be hazardous waste.
S^der^Tobtain a treatment facility permit, the facility would have to meet
the applicable Part 264 standards.
I* a waste does not, at pcesent, exhibit any of the characteristics of a
hazardous waste and that waste is subsequently listed as a hazardous waste, then
in oroeTto have the waste delisted the generator would have to demonstrate that
it does not posess the property for which it was listed. This delis ting would
require the filing of a formal delisting petition (see §§260.20 and 260.22).
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If a foundry applies for anc receives a treatment facility permit for a.
waste, because the"waste exhibits one or more characteristics, the." the. pemit
remains valid ever, if the waste subsequently becomes c. listed hazardous
I hope these answers se'.-ve to adequately clarify the regulations. If you
need any additional information, please feel free to give me a call at 2C2-75S-91ST.
Sincerely,
/'" -i * f i
David Friedman
Manager, Waste Analysis Program
Hazardous i Industrial Waste Division
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ENVIRONMENTAL ENGINEERING
& MANAGEMENT LIMITED
7400'Wetre 9ivc Suite -0!
Mmneaoolis. MN 55435 • Teieonone 6*2-831-2-3'
March 9, 1981
Mr . John Lehman
Environmental Protection Agency WH565
401 M Street S.W.
Washington, D.C. 20460 .
Dear Mr. Lehman:
I am seeking clarification regarding the appropriate approach to -
testing wastes from one of our clients.
The client is a gray iron foundry which utilizes a cupola for melting
its iron. The "cupola drop" after each charge has been designed
to fall to the floor onto a bed of material comprised mostly of
sands no longer useable for their original purpose in the foundry.
These sands come from six different locations in the foundry.
The cupola drop temperatures are high enough to have an effect on
the composition of the sands onto which they fall. For example, they
could partly or completely oxidize phenolic substances in the sands.
Visually,.changes can be observed in the sand's colors after the
cupola residue is dropped on them.
•
Our questions are as follows:
1. It can be documented that the procedure of dropping the cupola
residue on the sands has been a long standing practice.at this
foundry. Is it acceptable to the Environmental Protection
Agency to testvthe combined sands and cupola drop as a-single
waste stream? If not, what should be tested (i.e. all six
sources)?
2. If the cupola dusts from this foundry are shown to be hazardous
as a result of testing by the EP procedure., but a test of the
composite of all waste is not, is this an adequate basis for
proposing that the plant seek a permit as a treatment facili'tr?
If not, what additional tests are required?'
3. If the cupola dusts from this foundry are not found hazardous
by the EP procedure (assume single test), will it be necessary
to formally go through a delisting process if later this year
the EPA lists foundry wastes from cupolas?
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Mr. John Lehman
March 9, 1981
page 2
4. If the foundry obtains a license as a treatment facility
before any action is taken on dusts relative to its listing,
and subsequently cupola dusts are listed, what actions are
needed to preserve the treatment permit?
Your prompt review .of this matter is- necessary to assist us in
helping our client reach compliance within the earliest possible
time frame. If we can be of assistance to you, please call me at
612-831-2480. We are requesting that a written response be sent to
us for documentation. Thank you.
Sincerely,
CarWPerk.et, P. E .
ENVIRONMENTAL ENGINEERING
& MANAGEMENT, LTD.
cc: Mr. Alan Corson
Mr. David Freidman
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