Iowa

Overview of foundry sand reuse rules

Used foundry sands meeting concentration criteria (90 percent of federal RCRA TCLP leachate concentration limits) can be beneficially reused.  Beneficial use does not require a permit, however, it does require the development of a foundry sand management plan.  Also, an annual report must be prepared and kept on site for at least five years.

What reuse options are acceptable?

There are two categories of sand reuse options in Iowa:

• Uses for Which No Authorization Is Required.  Foundry sand may be used for the following purposes without authorization:
• Raw material in the manufacture of asphalt products,
• Raw material in the manufacture of cement or concrete products,
• Leachate control drainage material at a sanitary landfill,
• Subbase for hard-surface road construction,
• Fill material,
• Emergency flood control use for sandbags, and
• Alternative cover material at a sanitary landfill.

• Beneficial Uses for Which Applications are Required.  Foundry sand may be used for other beneficial purposes once a beneficial use permit is issued by the Iowa DNR (see application process below).

What restrictions apply?

All beneficial uses must meet the following requirements:

Iowa DNR established thresholds equivalent to 90 percent of federal RCRA TCLP leachate concentration limits found in 40 CFR 261.24. Any spent foundry sand possessing leachate concentrations less than or equal to these criteria (see below) is considered acceptable for reuse. Also, the spent sand must be evaluated for pH using EPA Method 9045 and must possess a pH greater than or equal to 5.0 and less than or equal to 10.0 for reuse.

Constituent	Threshold, mg/L
Arsenic	4.50
Barium	90.0
Benzene	0.45
Cadmium	0.90
Carbon Tetrachloride	0.45
Chlordane	0.027
Chlorobenzene	90.0
Chloroform	5.40
Chromium	4.50
o-Cresol*	180.0
m-Cresol*	180.0
p-Cresol*	180.0
Total Cresols*	180.0
2,4-D	9.0
1,4-Dichlorobenzene	6.75
1,2-Dichloroethane	0.45
1,1-Dichloroethylene	0.63
2,4-Dinitrotoluene	0.117
Endrin	0.018
Heptachlor (and its epoxide)	0.007
Hexachlorobenzene	0.09
Hexachlorobutadiene	0.45
Hexachloroethane	2.70
Lead	4.50
Lindane	0.36
Mercury	0.18
Methoxychlor	9.0
Methyl Ethyl Ketone	180.0
Nitrobenzene	1.80
Pentachlorophenol	90.0
Pyridine	4.50
Selenium 0.90	Silver 4.50
Tetrachloroethylene	0.63
Toxaphene	0.45
Trichloroethylene	0.45
2,4,5-Trichlorophenol	360.0
2,4,6-Trichlorophenol	1.80
2,4,5-TP (Silvex)	0.90
Vinyl Chloride	0.18

*If o-, m-, and p-cresols cannot be individually measured,

Do I need a permit?

As indicated above, certain beneficial uses of waste foundry sand do not require authorization.  For all other beneficial uses, the foundry must submit an application to the Iowa DNR so that DNR can make a “beneficial use determination.”  The required information for the application can be found in IAC 567-108.5 (455B, 455D).  It includes facility information, a description of the waste, chemical/physical waste properties, and market information.

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

A representative sample of leachate must be extracted by TCLP for classification of the spent foundry sand for beneficial reuse. The pH must be analyzed using EPA Method 9045. Quarterly sampling is required during the first year of each foundry sand beneficial reuse effort to establish a baseline, after which sampling must be conducted annually. In addition, current accumulations of used foundry sand may be made available for reuse and incorporated in the foundry sand management plan, provided that representative samples are taken to ensure compliance.

Where can I get testing performed?

List test regional labs.

What reporting and recordkeeping requirements must I meet?

A foundry must develop a sand management plan, which must include the following information:

• Description of a compliance assurance and sampling procedure to ensure that only foundry sands acceptable for reuse are accumulated and used. The defined sampling program must include, at a minimum, quarterly sampling for the first year, as a baseline, followed by annual sand sampling thereafter.
• Identification of storage site management controls for dust, stormwater runoff, and public access.
• An annual summary of how the spent sand was used. The annual report must be completed by March 1 of the following year and must be kept on site for at least five years, although the foundry need not submit it to Iowa DNR.

What other requirements must I meet?

None identified.

More information

Most relevant regulation/policy:  Iowa Administrative Code Section 567, Chapter 108 -- Beneficial Use Determinations: Solid By-Products as Resources and Alternative Cover Material.

State Solid Waste Regulations: Solid Waste Permitting.

Responsible Waste Division: Iowa DNR Land Quality.

State agency point of contact:

Brian Tormey
Department of Natural Resources
(515) 281-8927
Brian.Tormey@dnr.state.ia.us

Applicable case studies: None located.

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