Illinois

Overview of foundry sand reuse rules

Waste is managed by the Illinois Environmental Protection Agency (IEPA) according to the regulations in Subtitle G within Title 35 of Illinois’ Administrative Code.  Subtitle G addresses hazardous waste management, as well as solid waste management.  The regulations address the beneficial reuse of foundry waste. 

 

There are four classifications for foundry wastes:

  • Beneficially Usable Waste;
  • Potentially Usable Waste;
  • Low Risk Waste; and
  • Chemical Waste. 

The Beneficially Usable Waste classification category is the only category that qualifies foundry sand for reuse.  If the foundry sand is categorized in one of the other three classes, it must be sent to a landfill that is permitted to receive that category of waste.

What reuse options are acceptable?

Illinois’ requirements for reuse of foundry sand for land reclamation purposes are similar to siting or location restrictions.  If a generator proposes land reclamation as the beneficial reuse, the generator must also demonstrate that the use will not cause an exceedance of the applicable Illinois groundwater quality standards.

 

Land reclamation is related to strip mining activities, in which coal is extracted from narrow subsurface seams at shallow depths.  Once the coal is extracted, the seam needs to be backfilled to reclaim the land, and foundry sand is one material that may be used for backfilling. 

 

As long as the foundry sand meets the constituent concentration thresholds for the “beneficially usable” waste classification category, generators may pursue reuse activities without state approval. 

What restrictions apply?

Section 817.202(b) outlines restrictions associated with the storage of foundry sand.  Generators may store foundry sand for no longer than one year, unless the generator can prove that stored foundry sand has been added to or removed from within the past year. With this proof, the generator may continue to store the foundry sands for an additional six months. After this period of time, the storage pile site must be regulated as a landfill.

Do I need a permit?

The foundry sand beneficial reuse program is a self-implementing program. According to IEPA, the agency does not inspect reuse activity locations unless they receive complaints from the public that are related to the reuse activity. 

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

Although Illinois has a waste classification program structure, the state does not review proposed beneficial reuse activities for foundry sand.  Once a generator determines that the leachate from foundry sand meets the standards for a “beneficially usable” waste using the TCLP, the generator may pursue any reuse alternative that will not adversely affect human health or the environment, without notifying IEPA.

 

As long as the proposed reuse meets all other applicable requirements, “beneficially usable” wastes can be used in any application that does not create a threat to human health or the environment. If used foundry sand does not meet the beneficial reuse standards, a facility must file a “Petition for an Adjusted Standard” with the Illinois Pollution Control Board, which triggers a review of the proposed beneficial reuse project. 

What testing do I need to perform?

The Illinois Administrative Code establishes maximum allowable leaching concentrations (MALCs) to determine whether a waste is “beneficially usable.”  Twenty-five of the parameter limits are based on federal National Primary Drinking Water Standards, and another seven are based on federal National Secondary Drinking Water Standards.  IEPA may allow a generator to reuse foundry sand that exceeds the secondary standards.  To receive this exemption, the generator must submit an application to IEPA and show that although the foundry sand exceeds secondary standards, the state's groundwater quality standards will not be exceeded.

 

The generator must use a representative sample of leachate extracted by TCLP using deionized water (ASTM Method D3987-85) from each waste stream to characterize the expected constituents and concentrations of the leachate.  Generators must obtain representative samples of waste streams to be tested using ASTM Method D2234-76.  IEPA explained that the methods are complicated and are meant to provide guidance to the analytical chemist who would conduct the testing of foundry sand for the generator.  The agency does not appear to have any guidance on the methods and refers o the ASTM standard for further explanation on the test methods.

 

In addition, if the generator proposes land reclamation for the beneficial reuse, the generator must demonstrate that the use will not cause an exceedance of the applicable Illinois groundwater quality standards. 

The generator must test all individual waste streams annually.  Additional testing is required if there is a change in raw materials resulting in a change in the waste’s classification, a change in the manufacturing process or the waste's leachate characteristics, or if a new process is added that may generate a new waste material.

Where can I get testing performed?

List test regional labs.

What reporting and recordkeeping requirements must I meet?

The generator must submit to IEPA a certification containing the following information for each new recipient of the beneficially usable foundry sand and for each new use location:

 

(1) A detailed description of the process generating the material and the proposed use;

(2) A demonstration that the proposed use will not cause an exceedance of any standards and will not adversely affect human health or the environment;

(3) A physical description and analysis of the waste stream;

(4) The results of leachate testing; and

(5) Any available groundwater monitoring data.

What other requirements must I meet?

Although the generator may pursue any reuse alternative that will not adversely affect human health or the environment without notifying IEPA, the agency may seek enforcement action against generators who fail to satisfy any regulatory requirements.

More information

Most Relevant Regulation/Policy: Beneficial use regulations pertaining to foundry sand: Subtitle G within Title 35 of Illinois’ Administrative Code.

State Hazardous Waste Regulations: http://www.ipcb.state.il.us/SLR/IPCBandIEPAEnvironmentalRegulations-Title35.asp

 

Regulation/Policy Website: None identified.

Responsible Waste Division: Illinois Environmental Protection Agency Bureau of Land

State Agency Point of Contact: This is a self-implementing program.  No contact person has been assigned to this program.

Applicable Case Studies: None

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