Alabama

Overview of foundry sand reuse rules

Solid waste in Alabama is managed according to Division 335-13 of Alabama’s Administrative Code of regulations.  The Alabama regulations do not explicitly address beneficial reuse of solid waste in general.  Instead, the regulations specifically allow for the reuse of foundry sand through its “Requirements for Management and Disposal of Special Waste” in Chapter 335-13-4.26 (3). 

 

Alabama has a single-tiered waste classification structure for foundry sands.  Foundry sands that exhibit less than 50 percent of toxicity characteristic (TC) levels for metals as defined by EPA’s Toxicity Characteristic Leaching Procedure (TCLP) may be beneficially reused.  If foundry sands do not meet this requirement, they must be managed at an approved recycle/reuse facility or a landfill approved and permitted for the disposal of foundry sands.

What reuse options are acceptable?

The foundry sand regulation was developed to allow foundries to use their sand as fill material onsite or offsite.  ADEM staff stated that they have received inquiries from foundries about other potential beneficial reuses.  For example, a foundry recently contacted ADEM to reuse of sands as road base.  The state acknowledged that as long as the project complies with the existing rule requirements, then the beneficial reuse is allowable.  Therefore, although the regulation was originally designed to cover one beneficial reuse activity (fill material), ADEM applies the regulatory requirements to other proposed beneficial reuse activities.  

 

When multiple foundries send sand to a particular reuse location, these sands may be mixed together and reused as long as each foundry maintains proper documentation and recordkeeping. 

What restrictions apply?

Alabama’s regulations specify location restrictions for foundry sand reuse activities.  Reuse activities are restricted from floodplains, wetlands, residential zones, and areas less than five feet above the uppermost aquifer. 

 

Alabama’s clear regulatory language assures generators that if reuse activities occur away from the identified areas, the activities are allowable. 

Do I need a permit?

None Identified.

What steps do I need to take to reuse my foundry sand?

Alabama has a single-tiered waste classification program structure and, although the state does not review proposed beneficial reuse activities for foundry sands, it does require analysis and certification of the foundry sand waste composition.  To certify the foundry sands, the generator submits a completed Solid and Hazardous Waste Determination Form and a TCLP Analysis for metals. 

Once the state receives this information from the generator, the state reviews the documentation.  The Alabama program is distinct in that ADEM reviews the constituent concentration levels rather than the generator’s proposed beneficial reuse activity.  Generators may consider this process to be less burdensome because the generator only needs to provide to the ADEM basic initial sampling and testing information on the foundry sand.  This initial review may also streamline the state’s approval process, and allow generators to proceed with reuse activities sooner than would be possible if the state conducted a more detailed review.  However, Alabama’s initial review may be too limited.  Specifically, since the state does not review beneficial reuse activities, there is a risk that the state may be allowing environmentally-risky beneficial reuse activities to proceed without sufficient examination. 

The agency sends a certification letter to the applicant, approving of the generator’s Solid and Hazardous Waste Determination Form and TCLP Analysis.  This is not in the regulations, but ADEM staff indicated this action is performed.

What testing do I need to perform?

Alabama’s Administrative Code of regulations specifies maximum allowable constituent thresholds, based on Resource Conservation and Recovery Act (RCRA) TC levels, to determine if a waste is beneficially reusable.  To be determined reusable, foundry sands must demonstrate constituent levels less than 50 percent of the TC levels for metals.  The TCLP Analysis must be submitted to ADEM along with a Solid and Hazardous Waste Determination Form.  The form must provide the name of the generator and describe the waste generating process, the physical state, and whether the sand will be used as a fill material. 

 

Additionally, the generator must contact the Water Division of ADEM to obtain any necessary General Stormwater and/or National Pollutant Discharge Elimination System (NPDES) permits for the reuse sites. 

Where can I get testing performed?

List regional labs.

What reporting and recordkeeping requirements must I meet?

Alabama requires quarterly testing and reporting of foundry sands to ensure that the waste continues to meet the constituent concentration levels.  In Chapter 335-13-4-.26(3)(c), the regulations state that a Solid and Hazardous Waste Determination Form and a TCLP Analysis be submitted to ADEM quarterly or whenever the production process changes in such a manner that would significantly alter the test results. 

 

The regulations also require that each foundry maintain records at the manufacturing facility.  These records include a description of the site where beneficial reuse occurs, the site’s location within a specific township and range, and the volume of sand at the location.  

What other requirements must I meet?

None identified.

More information

Most Relevant Regulation/Policy: Requirements for Management and Disposal of Special Waste in Chapter 335-13-4.26 (3)

State Hazardous Waste Regulations: Chapter 335 Hazardous Waste Management

 

Regulation/Policy Website: None identified.

Responsible Waste Division: None identified.

State Agency Point of Contact: None identified.

Applicable Case Studies: None

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