Industry Position Prevails in Point of Generation Debate with EPA.

On March 28, EPA issued a letter stating that foundry sand reused onsite within the sand loop, including shakeout, is a continuous industrial production process. Therefore, sands within the sand loop are not solid wastes. Only sand that has been removed from the sand loop "for disposal (or for subsequent treatment or storage prior to disposal)" is potentially a solid waste under the jurisdiction of the Resource Conservation and Recovery Act (RCRA) subtitle C. In addition, sands stored indoors for reuse within the sand loop are excluded from RCRA jurisdiction. While the letter does not address thermal sand reclamation specifically, AFS believes EPA's new position is favorable to thermal operations for purposes of sand reuse as well. AFS has been challenging EPA on this issue since March 1995. At that time, EPA issued its "initial conclusion" that the process of separating pieces of metal, fines, core butts, etc., at the shakeout table to create return sand was "reclamation of a spent material." Moreover, if th at sand exhibited a hazardous characteristic, it would be considered a hazardous waste and handled in accordance with the requirements under RCRA Subtitle C. The RCRA Working Group has been negotiating with the agency on behalf of the foundry industry. This group included Dan Oman, RMT, Inc., chairman of the RCRA Working Group, and Mark Remlinger, Matthews International, chairman of AFS Solid Waste and Water Committee. This group helped to set up tours for EPA policymakers at several Pennsylvania foundries--Matthews International, Donsco, Inc., Buck Co., Wilton Armetale and J. Walter Miller Co.--to illustrate how sand is used in the metalcasting process. For a copy of EPA's letter or more information on how this policy change may impact your foundry operations, please contact Amy Blankenbiller, AFS Washington office, at 202/842-4864.