Massachusetts
Overview of foundry sand reuse rules
The reuse of foundry sand in Massachusetts is governed by state solid waste management regulations. A working draft of new reuse guidelines is currently under consideration.
The Business Compliance Division of DEP is redesigning the state industrial by-product reuse regulations (or "beneficial use of secondary materials," as named by the potential regulation). Under these revisions, the secondary material must meet or exceed all standards either for the raw material it is replacing or for the product it will become. Either a risk assessment must be performed or risk management techniques must be in place. The applicant may be required to inform all property owners of the existence and location of secondary material on their property. The risk assessments may be based on the Incremental Lifetime Cancer Risk due to the material, the Hazard Index, or applicable or suitably analogous health standards. These could include one or more of the following state standards: Drinking Water
Quality Standards, Air Quality Standards, Contingency Plan Standards, or Surface Water Quality Standards. The permittee must keep records of ongoing beneficial reuse activities, including amounts, sources, and the results of any required testing specified in the permit. The proposed regulations also enable DEP to issue generic beneficial reuse determinations, which would allow any person or entity to engage in the reuse activity, given adherence to the requirements and conditions of the specified policy.
What reuse options are acceptable?
Massachusetts does not define "allowable reuse activities." The reuse applicant must describe how the "proposed utilization will result in a viable and beneficial substitution of a discarded material for a commercial product or commodity" and demonstrate that the proposed handling, storage, use, and end products "will not adversely affect the public health, safety or the environment." The local board of health comments on the application, and the Department of Environmental Protection (DEP) then makes a final determination as to whether the material will be handled in such a way that it will not become solid waste, whether the sand can be "feasibly processed and put to beneficial use" as specified in the application, and whether the proposed project can be completed in compliance with appropriate rules and regulations in such a way that will not cause an adverse impact.
Massachusetts is revising its regulations to allow several methods of making beneficial use determinations. The methods include: (1) a comparative analysis of products made with and without beneficial use determination material; (2) the use of suitably analogous regulatory standards from other programs; and (3) a formal risk assessment, when necessary.
What restrictions apply?
None identified.
Do I need a permit?
None identified.
What steps do I need to take to reuse my foundry sand?
Reuse applications are classified by the volume of material that is being reused. For uses requiring more than 20 tons of material for a single project, a separate application form is used.
What testing do I need to perform?
Sampling and testing requirements are not specified in the current Massachusetts regulations. With the application for reuse, a chemical and physical characterization of the potential reuse material, as well as identification of its quantity, quality, and source must be submitted. The chemical tests consist of pH, reactivity, TCLP testing, total metals, volatile organic compounds (VOC), and identification of any other appropriate constituents. For physical properties, size, density, percent solids, and liquid content must be specified. There is no set frequency for recharacterization, unless one is specified in DEP's approval of an application.
Where can I get testing performed?
List test regional labs.
What reporting and recordkeeping requirements must I meet?
None identified.
What other requirements must I meet?
None identified.
More information
Most Relevant Regulation/Policy: 310 Code of Massachusetts Regulations 19.060 (Beneficial Use of Solid Wastes)
State Hazardous Waste Regulations: Massachusetts Hazardous Waste Regulations
Regulation/Policy Website:
Responsible Waste Division:Bureau of Waste Prevention, Business Compliance Division
State Agency Point of Contact: Sean Griffin, Bureau of Waste Prevention, Business Compliance Division, 617-292-5967, sean.griffin@state.ma.us
Applicable Case Studies: None
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