Ohio

Overview of foundry sand reuse rules

In August 2006, Ohio EPA staff issued draft rules OAC 3745-525-801 through OAC 3745-525-811 for public comment pertaining to the beneficial use of solid waste. The draft rules were constructed to establish a system that will regulate persons generating wastes who want to beneficially use those wastes rather than sending them to a landfill.   Six pre-approved uses are currently identified in the rule, but Ohio EPA will be adding more as appropriate.  One of these is for foundry sand when used as a cold weather road abrasive. For uses not identified as pre-approved, case-by case determinations will be made. The procedure for proposing a case-by-case use can be found at: http://www.epa.state.oh.us/dsiwm/document/draftrule/3745-525-808_draft.pdf

Until the draft rules are made final, Ohio EPA will use the draft rules as guidance to approve beneficial use projects.

What reuse options are acceptable?

Depending on the concentration thresholds met by each waste, potential beneficial uses of spent foundry sand (and other wastes) include:

  • raw material in manufacturing another product;
  • stabilization/solidification of other waste (for disposal);
  • in-composting process (not post-composting additive);
  • anti-skid agent/road surface preparation material;
  • soil blending ingredient;
  • daily landfill cover;
  • structural fill;
  • pipe bedding;
  • sub-base or final cover for roads/parking lots;
  • generator give-away programs;
  • filling empty borrow pits; and
  • land application.

Types of prior approvals for foundry sand reuse projects (X indicates a need for prior approval, while other uses can be done with no approval):

X: Landfill daily cover (Not approved through BU program, but through landfill)

Landfill – other

X: Feedstock for Portland Cement manufacture (Not regulated by Ohio EPA)

X: Aggregate for Portland cement concrete (Not regulated by Ohio EPA)

X: Aggregate for Asphalt

X: Aggregate for CLSM/Flowable Fill

X: Aggregate for pre-cast concrete/bricks/blocks/etc. (Not regulated by Ohio EPA)

X: Structural fills & building bases

X: Road bases

X: Highway embankments

X: Manufactured soils

X: Composts & mulches

X: Nursery soils

Other: (list)

What restrictions apply?

To be eligible for beneficial reuse, leachate from a waste must at a minimum meet "non-toxic" thresholds, which under Ohio regulations are generally equivalent to 30 times the levels of Ohio's Drinking Water Standards (DWS) for arsenic, barium, cadmium, chromium, lead, mercury, and selenium. The numerical non-toxic criteria, in mg/L, include:

  • Arsenic - 1.5
  • Barium - 60.0
  • Cadmium - 0.15
  • Chromium - 3.0
  • Lead - 1.5
  • Mercury - 0.06
  • Selenium - 1.0 28

Also, foundry sand leachate must not exceed the following thresholds, in mg/L, for the spent foundry sand to be non-toxic:

  • Cyanide - 0.6
  • Fluoride - 12.0
  • Phenol - 10.5

Within the definition of "non-toxic waste," additional thresholds exist (20 times DWS, 10 times DWS, 5 times DWS, and DWS) to provide varying levels of beneficial reuse flexibility.

Do I need a permit?

Beneficial reuse of a waste covered by Ohio's policy document does not require a permit from Ohio EPA if the intended use complies with all the provisions in the policy document. However, the following general requirements apply to beneficial use projects:

  • The generating facility should first explore and implement all feasible alternatives to reduce the volume and toxicity of wastes, as well as on-site recycling or recovery;
  • The use cannot create a nuisance condition;
  • Storage piles at the site or facility where the material will be used or stored prior to use cannot create a nuisance condition and are subject to erosion control practices;
  • Waste may not be used, without a permit, in projects that would include placing the waste in a stream bed, wetland, leach field, or well, unless the waste is fully contained in a manufactured product.

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

Each of Ohio’s four categories represents combinations of beneficial uses and concentration thresholds that are similarly protective. Ohio EPA allows the most flexibility under Category 1 and the least flexibility under Category 4:

  • Category 1 uses do not require Ohio EPA review or notification and include the largest number of beneficial reuse types;
  • Category 2 uses do not require prior review but trigger "isolation distance" restrictions, and the facility generating the waste must submit an annual report describing each beneficial reuse project, the type and estimated volume of waste used, and leachate test results;
  • Category 3 uses require 30-day prior notification to Ohio EPA and trigger
  • "isolation distance" restrictions; and
  • Category 4 uses, including those not listed in the guidance document, require 60-day prior notification and Ohio EPA consent.

What testing do I need to perform?

Generally, the applicant must create three different composite samples from 6 to 12 discrete samples and apply the TCLP or modified TCLP (EPA Method 1311, ASTM D3987-85) to obtain an extract that can be analyzed for the following parameters: acidity, alkalinity, aluminum, arsenic, barium, cadmium, chlorides, chromium, copper, cyanide, fluoride, iron, lead, manganese, mercury, pH, phenol, selenium, specific conductance, sulfates, total dissolved solids, vanadium, and zinc. Ohio EPA requires three initial test results for each parameter, one for each of the three composite samples. If the beneficial use is in Category 3 or 4, the results must be submitted to Ohio EPA with the proposal. If the waste has been characterized in the previous 12 months and no changes have been made, those results may be used.

Alternatively, the applicant may use the statistical procedure set forth in EPA's Test Methods for Evaluating Solid Wastes, SW-486, to evaluate a larger database that is representative of the material (e.g., monthly analysis from the preceding 12 months). Annual tests must be performed on the waste materials, although the applicant generally does not need to submit the test results to Ohio EPA. The applicant must analyze the waste product whenever there is a change in the production process or raw materials. Any result that exceeds the non-toxic criteria must be reported immediately.

Where can I get testing performed?

List regional labs.

What reporting and recordkeeping requirements must I meet?

Category 2 uses do not require prior review but trigger "isolation distance" restrictions, and the facility generating the waste must submit an annual report describing each beneficial reuse project, the type and estimated volume of waste used, and leachate test results;

What other requirements must I meet?

More information

Most Relevant Regulation/Policy: Link(s) to beneficial use regulations pertaining to foundry sand: (general, not specific to foundry sand): http://www.epa.state.oh.us/dsiwm/pages/draft_rule.html#bendraft

State Hazardous Waste Regulations: http://www.epa.state.oh.us/dhwm/laws_regs.html

Regulation/Policy Website: http://www.epa.state.oh.us/dsiwm/pages/news_pages/n_benrules.html

Responsible Waste Division: Division of Surface Water

State Agency Point of Contact: Jacob Howdyshell, jacob.howdyshell@epa.state.oh.us

Applicable Case Studies: None

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