Tennessee
Overview of foundry sand reuse rules
The Division of Solid Waste Management within the Tennessee Department of Environment and Conservation (DEC) developed a policy for the beneficial reuse of nontoxic spent foundry sand. Each foundry engaging in beneficial reuse projects maintains internal chemical analysis records on its material, indicating the material’s non-toxic nature. Certain reuse methods require the submission of a notification to Tennessee DEC. Contaminant thresholds are based on TCLP limits.
What reuse options are acceptable?
Under Tennessee policy, the following beneficial reuses of "nontoxic" materials do not require divisional notification:
- Manufacturing Another Product. Use as a raw material in manufacturing another final product, e.g., grout, cement, flowable fill, lightweight aggregate, concrete block, bricks, asphalt, roofing materials, plastics, paint, glass, fiberglass, ornamental ceramics and other non-land applications. (Soil materials are excluded.)
- Stabilization/Solidification of Other Wastes (for disposal). Use as a stabilization/ solidification agent for other wastes to be disposed of at an approved facility.
- Use in a Composting Process. Use in a regulated composting process, not including post-composting additive or land application.
- Daily Cover/Final Cover of Landfills. Use as a daily or final cover at a solid waste landfill, if all technical specifications are met for this intended use and approved by a permit.
- Landfill Liner Protective Layer. Use as a protective layer for landfill liners as part of an approved permit for the landfill.
- Small Construction Projects. Projects using no more than 200 tons for any single project and in which the material is stabilized. State waters must not be affected by the project, and initial documentation of the nontoxic nature of the material must be filed with the Division of Solid Waste Management. Certain other uses require Division project review, prior to initiation of the activity:
- Structural Fill. Various structural fill uses are accepted, provided that the application will be below the final surface grade of the project when completed. Some examples are building-supportive base or foundation; foundation backfill; construction material for road bases, parking lots, and embankments; construction fill material for planned commercial and residential projects; and backfill materials for utility lines.
- Mines/Strip Mine Projects. Uses as fill in abandoned or closed mines or strip mine areas where the plans are approved by the Federal Office of Surface Mines and the Tennessee Division of Water Pollution Control, as appropriate.
- Other Uses. The Director may approve other uses on an individual basis if they are consistent with this policy and protective of human health and the environment.
What restrictions apply?
TN DEC policy on the beneficial use of spent foundry sand does not establish a waste classification system. All aluminum and ferrous foundry sand that meets the contaminant thresholds listed below may be reused. Reuses are classified according to whether they do or do not require divisional notification.
The leachate thresholds (in ppm) for beneficial use of spent sand, based on results of TCLP analysis, are as follows:
- Barium - 20.00
- Cadmium - 0.05
- Chromium - 1.00
- Copper - 13.00
- Cyanide - 2.00
- Lead - 0.50
- Mercury - 0.02
- Nickel - 1.00
- Phenol - 15.00
- Selenium - 0.5
In addition, total formaldehyde must be less than 300 ppm.
Do I need a permit?
What steps do I need to take to reuse my foundry sand?
What testing do I need to perform?
Foundries must analyze their residual sand every two years for specified contaminants, or whenever process changes occur that may affect the composition of the sand.
Where can I get testing performed?
List regional labs.
What reporting and recordkeeping requirements must I meet?
All projects require certain recordkeeping standards. Each foundry must maintain information on the amount of sand used; the nature, purpose, and location of its projects; records of chemical analysis, updated every two years; and any written approvals that are received from the Division of Solid Waste Management, as applicable.
For projects requiring divisional review, as specified above, foundries and the property owner of the reuse site must submit a notification form to the Division of Solid Waste Management. The major items covered in the form are:
- generator and proposed use of material;
- estimated volume of nontoxic foundry sand to be used;
- proposed silt/runoff control; and
- description of use location, including local land uses, soil types, floodplains, and ground and surface water locations.
What other requirements must I meet?
More information
Most Relevant Regulation/Policy: None found online
State Hazardous Waste Regulations: Chapter 1200
Regulation/Policy Website: None identifed
State Agency Point of Contact: Mike Apple or Jeff Norman, Division of Solid and Hazardous Waste Management, 615-532-0780, mapple@mail.state.tn.us, jnorman@mail.state.tn.us
Applicable Case Studies: None
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