Texas
Overview of foundry sand reuse rules
The Texas Commission on Environmental Quality (TCEQ) and the Texas Cast Metals Association (TCMA) worked cooperatively in developing the Beneficial Reuse of Foundry Sand Program in the state of Texas, which educates foundries on how to use sand to its greatest potential. Originally tied to a statewide effort to reduce solid waste going to landfills by 50 percent (the "Clean Texas 2000" program), TCMA first issued guidance on the beneficial reuse of foundry sand. In 2001, TCEQ published An Environmental Guide for Texas Foundries, which summarizes Texas’ industrial solid waste regulations 34 and contains a chapter devoted to beneficial reuse of foundry sand.
Depending on the particular characteristics of a sand wastestream, foundry sand might qualify as hazardous industrial waste, non-hazardous industrial waste, or "non-waste." TCEQ defines "non-hazardous wastes" as "any industrial waste that is not listed as hazardous and does not have hazardous characteristics." Non-hazardous industrial waste is then categorized into one of three classes. While all classes of solid waste may be beneficially reused in Texas, reuse of hazardous or Class 1 non-hazardous waste may be subject to more restrictions.
What reuse options are acceptable?
Foundry sand that is considered "non-waste" according to 30 TAC 335.1 is immediately eligible for any beneficial reuse; it is not necessary to notify TCEQ about the sand or its use. Non-hazardous waste (Classes 1, 2, and 3) is also eligible for reuse, but must meet additional requirements (discussed below). According to TCEQ, some uses of foundry sand include:
- cement, brick, and asphalt manufacture;
- concrete – pipe and block, prestress, ready mix, precast, etc.;
- sand-blasting media and non-skid treatments;
- geotechnical fill – structural, drainage, top cover at landfills, liner material systems;
- flowable fill, subgrade fill, road base, etc.;
- paint filler; and
- steel production.
Non-hazardous industrial waste is categorized into three classes. Class 1 waste presents the greatest potential for adverse impacts on human health and the environment, while Class 3 waste presents the least potential for adverse impacts.
Class 1. Due to the presence of certain constituents and properties, Class 1 wastes present the greatest potential for adverse impacts on human health and the environment. Class 1 wastes may require special handling.
Class 2. Class 2 waste is any individual waste or combination of wastes that both is not hazardous and poses less risk than Class 1 non-hazardous wastes, but does not meet the thresholds for Class 3 non-hazardous waste. These wastes are often disposed of in permitted municipal landfills.
Class 3. Class 3 wastes are considered the least threatening to human health and the environment. Class 3 waste is inert and essentially insoluble and includes such materials as brick, glass, plastics, and rubber. If essentially uncontaminated, these wastes are considered nonthreatening and can be accepted at all permitted landfills.
Non-hazardous foundry sand can also qualify as "non-waste" for beneficial reuse if it meets the following eight criteria for "recycling material:"
- Each constituent in the recycling material must also normally be found in the raw material it is replacing. If not, it must not present an increased risk to human health, the environment, or waters of the state.
- A legitimate market must exist for the recycling material as well as its products.
- The recycling material must be managed and protected from loss, just as raw materials, ingredients, or products would be.
- The quality of a product must not be degraded by replacing raw materials with recycling materials.
- The recycling materials must be used without processing or changing the properties of the materials; or the recycling materials must be a necessary ingredient in a production process, and they must either meet or exceed the specifications of the raw materials being replaced without treatment or reclamation.
- The recycling material must not be burned for energy recovery, used to produce a fuel, or be contained in a fuel.
- The recycling material may be used as a product itself or to produce products as it is generated without treatment or reclamation.
- During the calendar year (beginning January 1), a foundry must recycle at least 75 percent (by weight or volume) of the recycling material accumulated during the previous year.
What restrictions apply?
Leachate from non-hazardous waste must be evaluated for the presence of 135 constituents. Furthermore, for a waste to be a Class 3 waste, it must also be evaluated using a seven-day distilled water leachate test. The results of this test are compared to thresholds for 35 constituents, which are based on federal maximum contaminant levels (MCLs) and total dissolved solids. A subset of constituents and their thresholds for each type of leachate test is presented in Exhibit A-6 below:
Do I need a permit?
None identified.
What steps do I need to take to reuse my foundry sand?
Foundry sand that is considered "non-waste" according to 30 TAC 335.1 is immediately eligible for any beneficial reuse; it is not necessary to notify TCEQ about the sand or its use. Non-hazardous waste (Classes 1, 2, and 3) is also eligible for reuse, but must meet additional requirements (discussed below). According to TCEQ, some uses of foundry sand include:
- cement, brick, and asphalt manufacture;
- concrete – pipe and block, prestress, ready mix, precast, etc.;
- sand-blasting media and non-skid treatments;
- geotechnical fill – structural, drainage, top cover at landfills, liner material systems;
- flowable fill, subgrade fill, road base, etc.;
- paint filler; and
- steel production.
What testing do I need to perform?
No testing is required for reuse of material that qualifies as non-waste. Non-hazardous waste (all classes) is subject to several testing requirements: (1) leachate testing (e.g., TCLP for metals and other possible toxic constituents); (2) totals analysis for total petroleum hydrocarbons (TPHs); and (3) verification of the absence of polychlorinated biphenyls (PCBs). Generally, sand must be retested when there is a change in the foundry process generating the waste sand.
Where can I get testing performed?
List regional labs.
What reporting and recordkeeping requirements must I meet?
Generators of non-waste sand must maintain records on-site documenting the dates the sand was originally produced, when it was sent for reuse, how it is to be used, its composition and characteristics, where it is going for use, and why it is not a waste.
If classified as non-hazardous industrial waste, the sand and its proposed use or activity cannot result in discharges into or adjacent to surface waters, cause a nuisance, or endanger public health or welfare. Notification of the proposed sand use must be provided to TCEQ at least 90 days before the use or activity begins. Re-notification is necessary if the process generating the sand or its planned use changes significantly.
Manifesting, annual reports, and waste receipt summaries are required only if TCEQ specifically requests them.
What other requirements must I meet?
None identified.
More information
Most Relevant Regulation/Policy: Environmental Guide for Texas Foundries
State Hazardous Waste Regulations: Industrial Solid Waste and Municipal Hazardous Waste Regulations
Regulation/Policy Website: 30 Texas Administrative Code, Chapter 335, Subchapter R
State Agency Point of Contact: Technical Analysis Team, Industrial and Hazardous Waste Permits Section, 512-239-6412, email not specified
Applicable Case Studies: None
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