California

Overview of foundry sand reuse rules

California does not have a formal system in place to address beneficial reuse activities. Depending on the project, a proposed reuse activity involving foundry sand will require individual review by a combination of:

• California Integrated Waste Management Board (CIWMB),
• Department of Toxic Substances Control (DTSC),
• State Water Resources Control Board (SWRCB),
• Regional Water Quality Control Board (RWQCB), and
• local health or enforcement agency.

The CIWMB, DTSC and SWRCB are three of six boards, departments, and offices under the umbrella of the California Environmental Protection Agency (Cal/EPA).

The CIWMB has established a "Tiered Regulatory Structure" to provide a level of regulatory oversight commensurate with the impacts associated with a solid waste handling or disposal activity.  An applicant can petition the CIWMB to reclassify the reuse project as a nonpermit activity requiring less regulatory review.

What reuse options are acceptable?

California regulations address the recycling/reuse of RCRA wastes and additional materials classified by the State as hazardous wastes ("non-RCRA hazardous wastes"), and outline provisions for reusing these wastes as a material in manufacturing.  These provisions focus on testing to confirm the waste's composition and establishing that recycling/reuse is viable (e.g., the market for the material exists, the reuse does not constitute disposal, the material will not require processing or significant storage prior to reuse, see California Health and Safety Code, Section 25143).  Additional standards exist for composting facilities using organic wastes, but there are no regulations for composting or land application of materials containing other solid wastes.

What restrictions apply?

The only thresholds explicitly referred to by California environmental agencies are the RCRA toxicity characteristic leachate thresholds to determine if a waste is hazardous or nonhazardous.

Parameter	RCRA Toxicity Characteristic Leachate Thresholds, mg/l
Arsenic	5.0
Barium	100
Cadmium	1.0
Chromium	5.0
Lead	5.0
Mercury	0.2
Selenium	1.0
Silver	5.0

Do I need a permit?

California does not have a specific permit for sand reuse.  However, you must get approval from various agencies before initiating a reuse project.

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

Leachate testing is required to evaluate all industrial wastes. Depending on the waste classification sought by the applicant, additional testing is also required, including, at a minimum, whole effluent toxicity.

DTSC, which generally regulates hazardous and potentially hazardous wastes, may first need to review leachate testing and waste composition data to grant a waiver from hazardous waste regulations or reclassify the waste as non-hazardous "designated industrial waste."  Similarly, the water boards and CIWMB may review leachate data and whole effluent toxicity data to determine if the waste is an "inert waste," which is subject to fewer regulatory requirements than other waste categories.

Additional requirements depend on the proposed type of reuse:

• If the reuse will include soil operations or composting, then the State and Regional Water Boards must review the project in addition to the CIWMB, and each of these agencies can establish other requirements including public notification, siting limitations, additional testing, volume restrictions, special handling and storage requirements, etc.
• If the waste will be reused as a raw material in manufacturing, no Water Board review is required and the CIWMB is likely to establish less stringent requirements. In fact, the CIWMB has established a "Tiered Regulatory Structure" to provide a level of regulatory oversight commensurate with the impacts associated with a solid waste handling or disposal activity.  An applicant can petition the CIWMB to reclassify the reuse project as a nonpermit activity requiring less regulatory review (see Solid Waste Permitting and Enforcement Regulations - Title 14 California Code of Regulations, Division 7, Chapter 5, Article 3).

Where can I get testing performed?

List test regional labs.

What reporting and recordkeeping requirements must I meet?

What other requirements must I meet?

None identified.

More information

Most relevant regulation/policy:

State solid Waste Regulations:

Title 14, Natural Resources--Division 7, CIWMB

Title 27, Environmental Protection Division 2, Solid Waste

State hazardous waste regulations: California Code of Regulations (CCR), Title 22, Division 4.5

Responsible waste division:

State agency point of contact:

See contacts under CIWMB Permitting & Enforcement Division

See contacts under DTSC Hazardous Waste Management, Regulatory and Technology Development

Applicable case studies: None located

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