Wisconsin
Overview of foundry sand reuse rules
Wisconsin's beneficial reuse program consists of a five-tiered system based on leachate and totals standards for all non-hazardous industrial by-products. Within the overall program, Wisconsin has created a beneficial reuse characterization process that targets ferrous foundry sand waste. Once generators determine the category for an industrial by-product, they may pursue any of the reuse methods pre-approved for that category. In almost all cases generators must periodically recharacterize beneficially reused wastes, and in all cases they must submit an annual certification.
What reuse options are acceptable?
Wisconsin allows 12 methods of beneficial reuse, most of which are suitable for spent foundry sands, but does not allow landspreading. The Wisconsin DNR can be petitioned to allow additional reuses not specified in the regulations. The 12 types of reuse specified in the regulations are listed below (the categories that qualify for each reuse are listed in parentheses):
- raw material for manufacturing a product (1-5);
- waste stabilization/solidification (1-5);
- supplemental fuel source/energy recovery (1-5);
- landfill daily cover/internal structures (1-5);
- confined geotechnical fill, including commercial, industrial or institutional building sub-base; paved lot base, sub-base, and subgrade fill; paved roadway base, sub-base and subgrade fill; tank, vault, or tunnel abandonment; utility trench backfill; bridge abutment backfill; and slabjacking material (1-4);
- encapsulated transportation facility embankment (1-4);
- capped transportation facility embankment (1-3);
- unconfined geotechnical fill (1-3);
- unbonded surface course (1-2);
- bonded surface course (1-2);
- decorative stone (1-2);
- cold-weather road abrasive (1-2); and
- general beneficial use in accordance with Chapter NR 538 (1-2).
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
- X: Landfill – other
- X: Feedstock for Portland Cement manufacture
- X: Aggregate for Portland cement concrete
- X: Aggregate for Asphalt
- X: 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
- Manufactured soils
- Composts & mulches
- Nursery soils
- Other: (list)
What restrictions apply?
An industrial by-product must meet leachate standards to qualify for any of the categories, and for Categories 1 and 2, it must also meet total elemental standards. The standards for ferrous foundry sand for all categories, are presented in Exhibit A-7.
Wisconsin's waste classification system consists of standards for five categories of industrial by-products and appropriate uses for each category. Category 1 by-products may be reused in any of the 12 methods allowed by Wisconsin Department of Natural Resources (DNR), while Category 5 by-products are limited to four methods.
- Category 1 includes by-products that meet the most stringent leachate and total elemental standards.
- Category 2 includes by-products that meet leachate and totals standards that are generally less stringent than the Category 1 standards by an order of magnitude. In addition, Category 2 has standards for fewer constituents than Category 1.
- Category 3 includes by-products that meet the same leachate standards as Category 2, but do not need to meet the Category 2 totals standards.
- Category 4 includes by-products that meet leachate standards that are less stringent than the Category 2 and 3 standards by a factor of two to five. In addition, Category 4 has standards for fewer constituents than Categories 2 and 3.
- Category 5 includes by-products that are non-hazardous but do not meet any of the standards for Categories 1 through 4.
Within its beneficial reuse regulations Wisconsin makes specific provisions for ferrous foundry excess system sand, ferrous foundry slag, and coal ash. Only a subset of the constituents included in Wisconsin's general beneficial reuse regulations are applicable when characterizing each of these specific waste types. Non-ferrous foundry sands must receive specific department approval under the general beneficial reuse regulations.
Do I need a permit?
The “Beneficial Use of Industrial Byproducts Initial Certification” form must be completed and provided to the Department of Natural Resources prior to the initiation of the beneficial use of an industrial byproduct, when the classification of an industrial byproduct has changed or for the establishment of a storage facility for beneficial use of an industrial byproduct. Unless the certification form is filed under NR 538.14, Wis. Adm. Code, the beneficial use or storage of industrial byproducts may be subject to licensing and regulatory requirements
What steps do I need to take to reuse my foundry sand?
The first step is to characterize the byproduct material(s) that your company intends to beneficially use. Once the byproduct material has been characterized properly and the results of the characterization sent to the Department, your company may proceed to beneficially use this material. Most beneficial uses allowed under this rule can proceed without specific departmental approval; however, regional staff assigned to the beneficial use program review larger proposed projects to allow for the evaluation of potential impacts to human health or the environment. The regional office staff of the program also review and approve beneficial uses for industrial byproducts which are not specified by rule and evaluate other waste materials for beneficial uses. Once you qualify for participation in the program you will be required to keep records of your beneficial use projects, report the amount of material you generate and beneficially use to the department annually, and retest your byproduct material at designated yearly intervals.
What testing do I need to perform?
All sampling and analysis must be performed using EPA's Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, and the sample collection and testing should be representative of the waste. A composite sample may need to be collected from several locations or over a specific time period, and the sampling technique must be adequately documented.
The most recent TCLP leachate test and total elemental analysis are applicable for Categories 1 and 2. For Categories 3 and 4 only the TCLP test applies. A by-product qualifies as Category 5 by simply not being a hazardous waste.
If the reuse material is used or stored in quantities that exceed 1,000 cubic yards per year over the previous authorization period, the applicant must recharacterize beneficially reused wastes based on a schedule contingent upon the waste category,. Specifically, the required recharacterization frequency is: Category 1 - every year; Category 2 - once every 2 years; Category 3 - once every 3 years; Category 4 - once every 5 years; and Category 5 - only when there is a change in the process that generates the industrial by-product.
Where can I get testing performed?
List regional labs.
What reporting and recordkeeping requirements must I meet?
Applicants must submit initial and annual certifications that document how the waste was generated, past and future beneficial methods, the most recent characterization testing results, any problems encountered during the previous year, and any environmental monitoring data collected during the past year at the beneficial reuse location.
What other requirements must I meet?
- Beneficial reuse cannot create nuisance conditions at the reuse location or at storage locations.
- Public notice and public participation requirements, depending on the volume of waste to be reused.
- For certain projects (confined or unconfined geotechnical fill and bonded or unbonded surface course) that will contain by-product volumes over set thresholds, written notification must be submitted to the Wisconsin DNR prior to initiating the project. For large transportation facility embankment projects (greater than 100,000 cubic yards), Wisconsin DNR concurrence must be obtained prior to initiating the project.
- Monitoring of leachate volumes is required for the fully encapsulated or capped transportation facility embankment uses, with chemical analysis of the leachate required if the volume exceeds certain thresholds.
- The beneficial reuse of industrial by-products is prohibited under various performance standards if any of the following will occur: (1) a significant adverse impact on wetlands; (2) a significant adverse impact on critical habitat areas; (3) a detrimental effect on any surface water; (4) a detrimental effect on ground water; (5) an excessive accumulation of explosive gases; or (6) the emissions of any hazardous air contaminant exceeding state limitations.
More information
Most Relevant Regulation/Policy: Beneficial use regulations pertaining to foundry sand: (general, not specific to foundry sand): http://www.legis.state.wi.us/rsb/code/nr/nr538.pdf
State Hazardous Waste Regulations: Wisconsin Hazardous Waste Regulations
Regulation/Policy Website: http://www.dnr.state.wi.us/org/aw/wm/solid/beneficial/index.html
Applicable Case Studies: None
Back to choose another state. |
