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CIAFS Indianapolis. Presentation: February 9, 2004. Outline. IDEM’s Top Compliance Issues P2 Technology: GM Bond P2 Technology: Advanced Oxidation. IDEM’s Top Compliance Issues. Waste determination Waste classification Reuse authorization Inadequate or inappropriate treatment

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ciafs indianapolis

CIAFS Indianapolis

Presentation: February 9, 2004

outline
Outline
  • IDEM’s Top Compliance Issues
  • P2 Technology: GM Bond
  • P2 Technology: Advanced Oxidation
idem s top compliance issues
IDEM’s Top Compliance Issues
  • Waste determination
  • Waste classification
  • Reuse authorization
  • Inadequate or inappropriate treatment
  • Indefinite storage
  • Unpermitted disposal
  • Internal housekeeping
  • External housekeeping
  • Storm water releases
idem s top compliance issues4
IDEM’s Top Compliance Issues

1. Waste determination:

  • Answers the question: Is the material a solid waste, hazardous waste, or other regulated waste?
  • Made on individual waste streams at the point of generation
  • Generator knowledge is acceptable
  • Representative sampling and good lab data
  • Must keep good records to support decisions
  • Hazardous: Determine hazardous wastes and constituents
  • Solid: All wastes going into a municipal solid waste landfill
  • Definitions: IC 13-11-2-205, 40 CFR 261, 329 IAC 10-2-174
idem s top compliance issues5
IDEM’s Top Compliance Issues

1. Waste determination

Potential wastes from pattern making:

  • Scrap patterns (wood, plastic, metal, wax)
  • Adhesive wastes
  • Solvents from cleaning
idem s top compliance issues6
IDEM’s Top Compliance Issues

1. Waste determination

Potential wastes from mold & core preparation and pouring:

  • Green and core sands
  • Damaged cores
  • Emission dust
  • Wastewater (if mold is water-cured)
  • Spent plaster
  • Waxes
  • Plastics
  • Waste resins and binders
idem s top compliance issues7
IDEM’s Top Compliance Issues

1. Waste determination

Potential wastes from furnace charge prep & metal melting:

  • Slag
  • Baghouse dust
  • Wet scrubber sludge
  • Spent ladles
  • Spent refractory
idem s top compliance issues8
IDEM’s Top Compliance Issues

1. Waste determination

Potential wastes from shakeout, cooling and sand handling:

  • Used sand
  • Sand lumps
  • Baghouse or emission dust
idem s top compliance issues9
IDEM’s Top Compliance Issues

1. Waste determination

Potential wastes from quenching, finishing, cleaning, and coating:

  • Risers, runners, spurs (from gating)
  • Metal fins
  • Sand blasting sands
  • Steel shot blast
  • Solvents
  • Acids
  • Salt baths
  • Coatings
  • Quench bath or sludges
  • Cutting oils
idem s top compliance issues10
IDEM’s Top Compliance Issues

1. Waste determination

Potential miscellaneous wastes:

  • Light bulbs
  • Batteries
  • Used oil
  • Used shop rags
idem s top compliance issues11
IDEM’s Top Compliance Issues

2. Waste Classification:

  • For disposal of a waste into a restricted waste site other than Type 1
  • For beneficial reuse
  • Found in solid waste rule (329 IAC 10-9-4)
  • Requires detailed chemical, technical, process, and regulatory knowledge
  • Requires representative sampling, good lab data, and QA/QC
idem s top compliance issues12
IDEM’s Top Compliance Issues

2. Waste classification:

  • Issued by IDEM
  • No application form
  • No fee!
  • Make a list of wastes and disposition
  • Review hazwaste determination
  • Collect documentation
  • Prepare sampling and analysis plan and submit to IDEM (not required, but helpful)
  • Update every two years
idem s top compliance issues13
IDEM’s Top Compliance Issues

3. Reuse authorization:

  • Type 3 foundry sand may be reused without state authorization
  • Any reuse of foundry waste other than foundry sand or (foundry sand other than type 3) must be approved by IDEM
idem s top compliance issues14
IDEM’s Top Compliance Issues

4. Inadequate or inappropriate treatment:

  • Hazardous waste must be treated to a standard for the hazardous characteristic
  • Underlying hazardous constituents must be treated to the universal treatment standard
  • Must develop and follow a waste analysis plan
  • Prior to point of generation treatment must have a waste analysis plan and demonstrate adequate and effective daily treatment
idem s top compliance issues15
IDEM’s Top Compliance Issues

5. Indefinite storage:

  • Not allowed by IDEM
  • Storage must not exceed 6 months
  • Storage must not threaten human health and the environment
  • Storage over 6 months assumed to be disposal
  • Speculative accumulation not allowed
  • Need a known intended end use and user
  • Need known chemical/physical composition
  • Need known source of material, turnover ratio
idem s top compliance issues16
IDEM’s Top Compliance Issues

6. Unpermitted disposal:

  • Restricted Waste Sites (RWS) Type 1, 2, 3
  • All RWSs must be permitted before use
  • RWSs are designed according to the waste being disposed
  • Type 2 waste may be disposed in a Type 2 or 1 RWS (landfill)
  • Anything less may be allowed under 329 IAC 10-9-4(f) after demonstrating lower concentrations of waste chemicals in any leachate generated
  • Concerned over piles of sand, cores, refractory material, slag, trash, and baghouse dust on the ground; some seen in standing water
idem s top compliance issues17
IDEM’s Top Compliance Issues

7. & 8. Housekeeping, Internal and External:

  • Avoid unnecessary employee exposure
  • Avoid tracking wastes outside via equipment and staff
  • Prevent contamination to soil, surface water, groundwater and air
  • Report spills to IDEM: 888-233-7745
  • Containerize waste or place on impervious surface, protected from the environment
idem s top compliance issues18
IDEM’s Top Compliance Issues

9. Storm water releases:

  • Foundries may need a storm water permit
  • SIC codes
  • Storm water affected by industrial activity
  • Separate storm water sewer or point-source discharge to waters of the state
  • NOI, SWP3, Sampling, Inspections, Reporting
  • No-contact exclusion available
pollution prevention technologies
Pollution Prevention Technologies
  • GM Bond
  • Advanced Oxidation
pollution prevention technologies20
Pollution Prevention Technologies

GM Bond:

  • Protein-based binder used for internal cores at aluminum, iron and steel foundries
  • Made from renewable, natural resources
  • Developed at General Motors R&D Center
  • Hormel Foods granted sole license to evaluate the product
  • CERP study: Reduced VOCs and HAPs by 90%
  • Currently working with GM Gray Iron Foundry in Saginaw, MI
  • No Indiana foundries using it at present
pollution prevention technologies21
Pollution Prevention Technologies

GM Bond:

  • Easier to rid the metal casting of its internal sand core, eliminating the need to heat or hammer parts
  • Reduced operating costs
  • Recyclable
  • Create stronger, more complex cores
  • Reduces pollution
pollution prevention technologies22
Pollution Prevention Technologies

GM Bond Contact:

pollution prevention technologies23
Pollution Prevention Technologies

Advanced Oxidation:

slide24
What is Advanced Oxidation (AO) as used in the foundry industry ?

A “non-end of pipe” pollution prevention process that treats the city water used in a foundry’s sand molding operations.

slide25
Advanced oxidants (and reductants) are created in sand system process water with the addition of small amounts of ozone, hydrogen peroxide, and in the presence of intense sonication .

The two main types are:

AO-Clean Water: sand system tap water treatment only

AO-Black Water: Wet collector and/or dry dust collector bentonite clay reactivation and return to the sand system via an AO treated blackwater slurry

slide26
AO Clean Water System

The CLEAN WATER systems treat the city water used in a foundry’s greensand molding and sand cooling operations with advanced oxidants generated from the combination of ozone, hydrogen peroxide, and sonication.

slide27
AO Blackwater System

The BLACKWATER systems apply additional acoustic techniques to advanced oxidation treatment concepts in order to recycle the coal and clay from a foundry’s dust collection systems to reduce solid waste disposal and to further reduce bond consumption.

slide28
AO Core Room Odor Scrubber in operation at a California iron foundry. Integrates an advanced Sono-catalytic reactor, UV photo-catalysis and air phase wet oxidation with Clean Water AND Black Water AO systems.
slide29
AO SystemMotivations for Installation

Reduce organic pollutant emissions

  • Reduce smoke and odor in foundries
  • Reduce neighborhood odor complaints and associated legal costs
  • Reduce benzene and VOC emissions to meet regulatory limits
  • Reduce solid wastes

Improve sand system performance

  • Improve sand strengths  reduce mold cracking
  • Reduce bond consumption  save money
  • Improve the predictability of sand system properties
slide30
Clean Water

Blackwater From wet scrubbers

Dust Recycle via

Blackwater

Emission

Reductions

10-30% Benzene

20-40% VOC

20-50% Benzene

30-75% VOC

50% Benzene

30-90% VOC

Sand System

Performance

15-35%

less clay

used

20-35%

Less clay

used

27%-48%

Less clay

used

Other Benefits

Reduced in-plant smoke and odor

Reduced stack odor

Reduced build-up of condensables in ductwork

AO system performance summary

slide31
How does this compare to the published proposed new source MACT Standard of 20 ppmvVOCs for a sand system?AfterAOandoptimization:
  • A Wisconsin foundry has tested 1-18 ppmv on last certified stack test (EPA method 18 as propane) (Extremely heavy cored)
  • A Wisconsin foundry has tested 4-10 ppmv with heavy core load (WI Occupational Health Lab)
  • A Pennsylvania foundry has tested .8 to 3 ppmv after AAOP but before optimization is complete (EPA method 18 as hexane)
  • A heavily shell cored California foundry tested less than 6 ppmv.
  • A federally funded California research foundry has tested 14-16 ppmv via real-time FID (EPA method 25) of heavily cored engine block tests, lower on high surface area no-core. See graph provided.
slide32
This turbocharger core package generated

many smoke and odor complaints.

slide33
Turbocharger now produced

virtually smoke and odor free

after AO clay/coal recycle

and core room odor scrubbing

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