Pennsylvania
Overview of foundry sand reuse rules
The Pennsylvania
Department of Environmental Protection (DEP) issues general
permits for combinations of residual waste processing and beneficial use on
a regional or statewide basis. Once a general permit exists, beneficial
reuse is self-implementing. A facility interested in the beneficial reuse of a
particular waste is not required to obtain an individual permit. Instead, the
facility must apply for coverage under an existing general permit through a
determination of applicability and be able to demonstrate compliance with all
applicable requirements in the general permit.
Wastes must be similar physically and chemically and must be
used and processed in a similar fashion. If the waste is to be used as a raw material in a product or a
substitute for a commercial product, it shall meet or exceed the applicable
ASTM, DOT, National, state, local or industry standards or specifications for
the material being replaced.
What reuse options are acceptable?
An applicant may propose any combination of
residual waste processing and beneficial reuse for a general permit. Currently, there are four general permits
relevant to the foundry industry that are in effect or pending:
"Beneficial
use of waste molding sand from gray and ductile iron foundries for use as pipe
bedding," where the waste sand was generated in a no-bake molding process
(Permit
WMGR016). This applies to foundries in SIC Code 3321.
"Beneficial use of waste foundry sand for use as a
roadway construction material or as a component or ingredient in the
manufacturing of concrete or asphalt products" (Permit
WMGR019). This applies to foundries with SIC Codes 3321, 3322, 3325, 3365,
3369, 3532, 3568, and 3569, and applies only to waste foundry sand used with
the following sand binders or binder systems in their mold production
processes: phenolic urethanes, phenolic esters, phenolic hotbox, phenolic
no-bake, furan no-bake, furan warmbox, furan sulfur dioxide, alkyd urethane, alkyd oil based core oil, and epoxy
sulfur dioxide.
"Beneficial
use of waste foundry sand from an aluminum foundry for use as road bed
construction material" (Permit
WMGR021). This applies to foundries classified as SIC Code 3365.
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):
-
Landfill Daily Cover
- Landfill (other)
- Feedstock for Portland Cement manufacture
- X: Aggregate for concrete
- X: Aggregate for Asphalt
- Aggregate for CLSM/Flowable Fill
- X: Aggregate for pre-cast concrete/bricks/blocks/etc.
- X: Structural fills & building bases
- X: Road bases
- X: Highway embankments
- X: Manufactured soils (soil amendment/soil additive)
- Anti-Skid
- X: Pipe Bedding
- X: Other (Backfill for USTs)
What restrictions apply?
An applicant for a new general permit must
propose concentration limits for contaminants in the waste and a rationale for
those limits. In addition, if the waste is to be used without reclamation as a
construction material, soil additive, soil substitute or anti-skid material, or
otherwise placed directly onto the land, leachate from the waste cannot exceed:
-
25 times the
ground-water standards for metals and other cations; or
-
the
ground-water standards for contaminants other than metals and cations.
As a result, two general permits for similar
waste but proposing different beneficial uses could establish two different
sets of constituent concentration thresholds.
For pH, ignitability, and reactivity, as well
as for each contaminant subject to the hazardous waste toxicity characteristic, the maximum
concentration is equal to the value listed in Table 1 of 40 CFR Part 261.
In the three
general permits targeting foundry sands, DEP approved a different set of parameters for each permit and, in some
cases, different thresholds for the same constituent. Each general permit
contains totals and leachate standards, which are presented in Exhibit A-5
below.
Do I need a permit?
Generally. General
permits authorize combinations of residual waste processing and beneficial
use on either a regional or a statewide basis. General permits apply to all
beneficial reuse combinations that meet specific criteria and are not limited
to individual facilities.
Exceptions include uses as alternate daily
cover at permitted landfills, and cases that are covered by a co-product
determination.
A general permit application must include a
physical and chemical description and analysis of the residual waste, a
demonstration that the waste is non-hazardous, a description of how the waste
was generated, a description of the proposed use, and a demonstration that the
waste is capable of performing the desired functions in the intended use.
Persons
may be authorized to operate under an existing general permit via a
registration or determination of applicability or they may apply for apply for
a new general permit. Fees include: general permit - $2000, registration -
$250, determination of applicability - $500. General information required for permit approval includes description of
proposed beneficial use, detailed narrative of the production or manufacturing
process by which the waste was generated, proposed concentration limits for
waste contaminants, rational for these limits, detailed demonstration of the
efficacy of the waste for the proposed beneficial use.
What steps do I need to take to reuse my foundry sand?
Once a general permit has been issued, any
facility intending to beneficially reuse residual waste may do so through a Determination of Applicability without applying for or obtaining an
individual permit, provided the facility meets all requirements. Either DEP or
an outside applicant may initiate the process for the issuance of a new general
permit.
What testing do I need to perform?
When submitting a Determination of
Applicability or a new general permit application, the applicant must include a
full waste characterization, an evaluation of the
potential for the waste to leach into the environment, and a waste sampling
plan that ensures an accurate and representative sample used for these
analyses. Sampling and testing should use EPA SW-846, Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods, to determine compliance
with concentration standards. Applicants may use either the TCLP or the
Synthetic Precipitation Leaching Procedure (SPLP) to conduct leachability
evaluations on representative samples. The facility must propose a re-analysis frequency and the rationale for the specified
frequency.
In
the case of General Permits WMGR019 and WMGR08, waste foundry sand obtained
from storage or disposal stockpiles can be used for beneficial reuse if first
analyzed for compliance with the chemical thresholds specified in the permit.
Two additional requirements include:
- For inorganic
parameters, one grab sample for every 50 tons of waste foundry sand that are
excavated. Composite samples from the grab samples must then be formed and
analyzed after every 1,000 tons of waste sand excavated.
- For organic
parameters, one grab sample must be collected and analyzed for every 1,000 tons
of waste sand excavated.
Where can I get testing performed?
List regional labs.
What reporting and recordkeeping requirements must I meet?
The applicant must submit an annual report
that includes documentation of a recent waste analysis. For each new source of
waste, the permittee must submit an analysis of a representative sample of the
waste no less than 15 days prior to beneficial use.
The applicant must maintain records on site
for 5 years.
What other requirements must I meet?
-
If residual
wastes are blended for use, the applicant must demonstrate that each waste
results in a beneficial contribution to the use of the mixed waste and that the
consistency of the blend will be maintained.
-
The applicant
must provide written notice to each municipality in which the applicant intends
to operate under a general permit.
- The storage,
transportation, or use of the waste cannot create a nuisance or be harmful to
public health, safety, or the environment.
- The reuse
cannot cause ground-water or surface-water degradation.
- Furthermore,
the waste cannot be: (1) used as valley fill material, to fill open pits from
coal or other fills, or to level an area or bring an area to grade; (2) used
within 100 feet of a perennial stream; (3) used in or affecting "an
exceptional value wetland"; (4) used within 300 feet of a private or
public water source; or (5) used or stored in direct contact with ground water
or surface water.
More information
Most Relevant Regulation/Policy: Link(s) to
beneficial use regulations http://www.pacode.com/secure/data/025/chapter287/subchapHtoc.html
http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp?A=1239&Q=463011
State Hazardous
Waste Regulations: Article VII
– Hazardous Waste Management
Regulation/Policy Website: http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a=1239&q=462668
State Agency Point of Contact: Ron Hassinger, Bureau of Land
Recycling and Waste Management, 717-787-7381, rhassinger@state.pa.us
Applicable Case Studies: None
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