The lowest practical is phi
cv, or phi constant volume also called phi critical state (phi
cs), the friction angle for a sand at its lowest state of packing.
There are lots of tables on such value, a function of mineralogy, angularity, shape, grading (interlocking as cited) and more, its most common range for clean sands is 30-34°.
A very useful table for sands and gravel has been published by a BS 8002,1994 regulation I'm attaching it here, I find it very useful especially when dealing with gravels, even though not siliceous (please note

hi
cv = A+B in the attached table.
Salgado et al. have shown that some fine content (silt) in sand tends to increase phi
cv because it increases interlocking, so if phi
cv of a clean quartz sand is 33°, for example, the same sand with 15% silt may exhibit 35° and over (I just remember the values were pretty high, more than one may have thought).