West Virginia

Overview of foundry sand reuse rules

The Office of Waste Management within West Virginia’s Division of Environmental Protection (DEP) developed guidance specific to the beneficial use of "spent foundry sand (including molding sand and core sand) generated by metal casting foundries." Beneficial reuse of foundry sand requires a plan approval from DEP. The plan must detail the intended use of the spent sand, set out a sampling and testing plan for the sand (e.g., total metals and TCLP analyses), and demonstrate that the waste and its intended use do not pose a threat to human and environmental welfare (e.g., through meeting threshold concentrations of constituents of concern and meeting isolation distance requirements).

Spent foundry sands are managed by WVDEP specifically under Spent Foundry Sand Beneficial Use Guidelines, which took into effect June 1, 2000.  The guidelines apply to spent foundry sand (including molding sand and core sand) generated from metal casting foundries. Beneficial use of spent foundry sand requires a plan approval from WVDEQ Office of Waste Management, Solid Waste Management Section (SWMS).  Though a permit is not required, written approval from SWMS must be issued prior to activities associated with the proposed beneficial use.

 

The Beneficial Use Plan must include:  chemical and physical description of the waste, description of manufacturing/production process which generates the waste, sampling and analysis plan for the spent foundry sand (waste characterization using both TCLP and total metals), description of method of processing and/or beneficial use.  Ceiling analytical thresholds provided in Table I and II of the guideline. Guidelines also provide the allowed beneficial uses for spent foundry sand (Section VII).  These are:  manufacturing another product, stabilization/solidification of other wastes, anti-skid agent/road surface preparation material, daily cover for landfills, protective cover for landfill leachate collection system, structural fill (excluding valley fills or mine fills), pipe bedding, roads and parking lots, capped embankment, ground and site barriers.

What reuse options are acceptable?

West Virginia guidelines on beneficial use of spent foundry sand do not apply to wastes that are "Hazardous by Characteristic (as described in 40 CFR 261.24) or Listed Hazardous Wastes (described in 40 CFR 261.31, 261.32 and 261.33)." Allowed beneficial uses of spent foundry sand include:

  • Manufacturing Another Product. Use as a raw material in manufacturing another final product, e.g., grout, cement, concrete, asphalt, roofing materials, plastics, paint, glass, fiberglass, ornamental ceramics, rock wool, mineral wool, brick, plaster, and other similar products.
  • Stabilization/Solidification of Other Wastes. Use as a stabilization/solidification agent for other wastes to be disposed of at an approved facility.
  • Anti-Skid Agent/Road Surface Preparation Material. Use as an anti-skid material or road surface preparation material. Use must be consistent with WV Department of Highways or other applicable specifications.
  • Daily Cover of Landfills. Use as a daily cover at municipal solid waste landfills, if all technical specifications are met for this intended use.
  • Protective Cover for Landfill Leachate Collection Service. Use as a protective cover material located above the drainage layer of a municipal solid waste landfill, if all technical specifications are met for this intended use.
  • Structural Fill. As an engineered use, i.e., as a building or equipment supportive base or foundation. This category does not include valley fills or filling of open pits from coal or industrial mining.
  • Pipe bedding.
  • Roads and Parking Lots, Capped Embankment, Ground and Site Barriers. Use as construction material (sub-base) for roads or parking lots; "capped embankment," where an embankment supports a roadway or other structure whose side slopes are covered with soil suitable for the growth of normal vegetation; and "ground and site barriers," i.e., capped embankments for use as ground or site barriers as long, low, narrow structures lying above the existing ground surface. These structures do not support roadways or other structures and are capped with 24 inches of vegetative cover over their entire surface (where applicable). All activities in this category must be performed under the supervision of a professional engineer or the WV Department of Highways.

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
  • Aggregate for Portland cement concrete
  • Aggregate for Asphalt  
  • Aggregate for CLSM/Flowable Fill
  • Aggregate for pre-cast concrete/bricks/blocks/etc.
  • X: Structural fills & building bases 
  • Road bases 
  • Highway embankments 
  • Manufactured soils 
  • Composts & mulches
  • Nursery soils

What restrictions apply?

The leachate thresholds (in mg/L) for beneficial use of spent sand, based on results of TCLP analysis, are as follows:

  • Arsenic - 0.05
  • Barium - 1.0
  • Cadmium - 0.01
  • Chromium - 0.05
  • Lead - 0.05
  • Mercury - 0.002
  • Selenium - 0.01
  • Silver - 0.05
  • Cyanide - 0.6
  • Fluoride - 12.0
  • Phenol - 10.5

The total metals thresholds (in mg/L) for beneficial use of spent sand include:

  • Copper - 1500
  • Molybdenum - 18
  • Nickel – 200
  • Zinc – 2800

Do I need a permit?

Beneficial use of spent foundry sand does not require a permit. Reuse does, however, require plan approval from the SWMS. The major plan items are described below:

  • chemical and physical description of the waste (i.e., fully characterizing its composition and properties) and description of the manufacturing and production processes that generated the waste (e.g., including information on chemical constituents in all binders, coatings, or other chemicals used in the production process);
  • description of the use location, including topography, soil type, floodplains, and ground- and surface-water locations;
  • description of the method for processing and/or beneficial use; and
  • permanent, written consent from the landowner of the reuse site giving the WV DEP permission to enter the land.

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

DEP guidance on the beneficial use of spent foundry sand does not establish a waste classification system. Rather, it outlines a process for obtaining permission for use based on information characterizing the waste, its intended use, and a plan for managing the waste once it is used. All material must meet one set of leachate and total metals guidelines.

What testing do I need to perform?

Approved plans for reuse must contain a sampling and analysis plan (SAP). The SAP must be submitted to WV Office of Waste Management, Solid Waste Management Section (SWMS), for review prior to sample collection and testing. The laboratory and facility personnel use the approved SAP as a reference during all phases of sample collection and analysis. The following items are addressed in the SAP:

  • sample methods (3 composites for each source, each from 6 to 12 discrete samples);
  • toxicity testing and analysis (TCLP or variation thereof);
  • total metals testing and analysis (including copper, molybdenum, nickel, and zinc);
  • number of samples (three tests on each parameter);
  • parameters (i.e., constituents of concern); and
  • additional testing for continued beneficial use (i.e., minimum of annual testing) or when the production process or raw materials used in the production process change.

Where can I get testing performed?

List regional labs.

What reporting and recordkeeping requirements must I meet?

None identified.

What other requirements must I meet?

In addition, beneficial use projects must meet general requirements, such as storage, maintenance, and runoff control requirements; isolation distance requirements (varying minimum distance from streams, drinking-water wells, floodplains, public or private water sources, and groundwater); use restrictions (e.g., prohibited from use as a valley fill material, to fill open pits from coal or other fills, or to level an area or bring an area to grade where the construction activity is not completed properly after the placement of the material); and public health and safety concerns.

More information

Most Relevant Regulation/Policy: Beneficial use regulations pertaining to foundry sand: (general, not specific to foundry sand):

http://www.iofwv.nrcce.wvu.edu/metal/FOUNDRY.PDF

State Hazardous Waste Regulations: 33-20

Regulation/Policy Website: None found online

Responsible Waste Division: Office of Waste Management

State Agency Point of Contact: Sudhir Patel, Office of Waste Management, 304-558-6350 x265, spatel@dep.state.wv.us

Back to choose another state.