Ohio EPA Beneficial Use Program March 22, 2018 Ohio EPA Division of Materials and Waste Management Beneficial Use Group Harry Sarvis – Manager (Ph.D. Biochemistry) John Schierberl – Supervisor (M.S. Water Resources) Maera Flynn - Molecular Biologist (B.S. Molecular Genetics) Phil Cherosky – Engineer (M.S. Biological Engineering) Set up: Visits are long overdue We asked Kurt and Jen to ask who other than DMWM might benefit from/add value to this conversation kind of like my old job in enforcement we get to work with everybody so thanks to all you from other groups attending this morning also. John group introductions Set up We’re hear to talk a lot, but hopefully to listen a lot too Meant to be informal, if anyone has something to say speak up

Beneficial Use Webpage

Beneficial Use Authorizations Permits: general or individual Constituents of Concern appropriate for use (sampling and analysis) Operating conditions Best Management Practices - BMPs (storage and use) Reporting requirements Record Keeping (Legitimacy Criteria) Authorized in rule: no permit required if byproduct is used in a construction material meeting engineering specifications Encapsulation Legitimacy criteria Maera

Beneficial Use General Permit Permit issued by the director. Issued for five years. To apply for coverage, send in Notice of Intent (NOI). Contains operating conditions and constituents limits. Two foundry sand general permits. Example: Foundry sand used as an ingredient in a soil blend Phil

NOI

General Permit

Standards General Permits Unrestricted use Examples — soil blend and land application. U.S. EPA Regional Screening levels and/or U.S. EPA 40 CFR Part 503 Pollutant Concentrations. Leaching limits (TCLP or SPLP) for use as fill Foundry sands are 20 times MCL or SCL. Soil Screening Guidance: Technical Background Document https://www.epa.gov/superfund/superfund-soil-screening-guidance Appendix E: https://semspub.epa.gov/work/HQ/175217.pdf Maera

Beneficial Use Individual Permit Apply if you cannot operate or meet conditions in a general permit. If sand exceeds constituent limits of general permit, demonstrate how the use of sand will not adversely impact human health or safety or the environment. Beneficial use at an industrial site, groundwater is not used for drinking water Select BMPS to eliminate run off to surface waters Blend foundry sand to meet constituent limits (soil, compost, and EQ biosolids) and include confirmatory sampling Approval will depend on beneficial uses of the material, locations of the beneficial use, the constituents of concern in the material, volume of material, and a complete application. Phil For uses we are not as familiar with and/or cannot comply with conditions of the general permits

Comparison General Permit Individual Permit Demonstration waste is not hazardous Generator knowledge or TCLP Method 1311 data Complete NOI Sampling plan and analytical data Statistical analysis Fee of $200 Demonstration waste is not hazardous Complete individual permit application Initial foundry sand characterization demonstration with sampling plan & statistical analysis List of proposed uses BMPs necessary for each use Compliance demonstration Any other pertinent information Fee $350

Contact Information Harry Sarvis Harry.Sarvis@epa.ohio.gov (614) 644-3519 John Schierberl John.Schierberl@epa.ohio.gov (614) 644-2955 Maera Flynn Maera.Flynn@epa.ohio.gov (614) 728-5338 Phil Cherosky Phil.Cherosky@epa.ohio.gov (614) 644-3249

Discussion/Questions/Feedback? Ohio EPA Division of Materials and Waste Management Beneficial Use Group