A brass foundry operation located in Illinois manufactures brass and bronze castings for use in the plumbing industry, irrigation/sprinkler industry and other specialized industries. In the course of the casting manufacturing process excess/unusable sand is generated from the facility. Some of this sand was temporarily stored on a concrete pad outside the facility prior to treatment and disposal. During a routine inspection by the Illinois Environmental Protection Agency (IEPA) the inspector noted a small amount of sand on the concrete pad and collected a sample for laboratory analysis. The laboratory analysis indicated that the sand exceeded the limit for lead (Pb) and was considered a RCRA waste. Based on the results of the site inspection and the laboratory analytical the IEPA issued a Notice of Violation (NOV) letter to the facility.
We were retained to assist the facility in complying with the NOV in an effort to ultimately obtain closure of the NOV. After receiving the NOV, representatives from Free Flow and the foundry met with IEPA representatives in Springfield, Illinois to propose and agree on a compliance strategy/plan in and effort to comply with the NOV.
A proposed RCRA Closure Plan was prepared and submitted to the IEPA to review and approve. Upon receipt of IEPA approval Free Flow and foundry personnel implemented the closure plan. The closure plan consisted on removing the existing broken and cracked concrete pad, removing the top layer of underlying soil and collecting samples for laboratory analysis of Lead (Pb). After determining that the underlying soil was clean the foundry poured a new concrete pad.
A RCRA Closure Report was then prepared and submitted for IEPA review and approval. The completion of the closure plan and closure report resulted in a clean closure approval from the IEPA.