Rhode Island
Overview of foundry sand reuse rules
The Rhode Island Department of Environmental Management (RIDEM) established guidelines for beneficially reusing source-segregated solid waste in 1999. These guidelines outline RIDEM's approach for evaluating whether specific source-segregated solid waste (i.e., separating the proposed "useful" materials from the wastestream at the point of generation) that were not previously defined as recyclable materials may be reused.31 The process by which RIDEM reviews a request to reuse a specific source-segregated solid waste is referred to as a "Beneficial Use Determination" (BUD).
What reuse options are acceptable?
RIDEM does not indicate allowable reuses, except to outline additional requirements for land application and manufacturing soil products. All proposed reuses are evaluated on a case-by-case basis.
What restrictions apply?
RIDEM has not developed thresholds specifically for BUDs. For land applications, however, RIDEM will rely on components of the Rules and Regulations for the Investigation and Remediation of Hazardous Material Releases - Rule 8.02 (Residential Direct Exposure Criteria) and Rule 8.8.00 (Compost Product Requirements and Distribution) to guide its evaluation.
Do I need a permit?
The applicant must first request a variance from the Solid Waste Regulations. By granting a variance, RIDEM is reclassifying a waste as a reusable source-segregated solid waste. Variances expire after one year unless otherwise directed by RIDEM, and renewal of a variance must be requested at least 60 days before the expiration of the existing variance. Positive BUD reviews result in reuse permits for an initial period of one year, which may be renewed for a period of three years.
What steps do I need to take to reuse my foundry sand?
To request a BUD for a proposed beneficial use, the applicant must first request a variance from the Solid Waste Regulations. By granting a variance, RIDEM is reclassifying a waste as a reusable source-segregated solid waste. Variances expire after one year unless otherwise directed by RIDEM, and renewal of a variance must be requested at least 60 days before the expiration of the existing variance. Positive BUD reviews result in reuse permits for an initial period of one year, which may be renewed for a period of three years.
What testing do I need to perform?
Applicants for reuse projects, typically the end user, must include a characterization plan describing methods for sample collection and analyses, and demonstrating that the characterization will be representative of the waste material. This plan must consider: how the samples will be collected, what types of samples to collect, what type of physical and chemical analyses should be performed, what substances are present in the waste (and what is their variability), and what are the human health and ecological risks associated with beneficially using the solid waste in the manner proposed.
Where can I get testing performed?
List regional labs.
What reporting and recordkeeping requirements must I meet?
What other requirements must I meet?
- minimizing or eliminating the environmental hazards associated with the proposed recycling of solid waste;
- demonstrating that the reused material is a viable substitute for traditional raw materials;
- demonstrating that the proposed reuse will not adversely impact public health and natural resources, including ground water, surface water, air, or other applicable environmental resources;
- assessing the extent to which an end market exists for the reusable material;
- describing the reuse and the controls that will be in place;
- demonstrating that the proposed reuse is not simply an alternate method of disposal; and
- describing the degree of processing the solid waste material has undergone and the degree of further processing that is required.
- In addition, RIDEM may require the applicant to post public notice regarding the proposed BUD and/or hold a public workshop or hearing to allow for public participation.
More information
Most Relevant Regulation/Policy: Guidelines on Beneficial Use Determinations ("BUDs") for Source Segregated Solid Waste
State Hazardous Waste Regulations: http://www.dem.ri.gov/pubs/regs/index.htm#WM
Regulation/Policy Website: www.state.ri.us/dem/pubs/regs/index.htm#WM
State Agency Point of Contact: Chris Shafer, Waste Management Division, 401-222-2797 x7511, cschafer@dem.state.ri.us
Applicable Case Studies: None
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