Foundry Sand Reuse in Alabama | Foundry Recycling Services

Planning to reuse spent foundry sand in Alabama? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what ADEM needs before the sand can be reused.

Key terms

Spent foundry sand

Foundries bond silica sand into molds and cores for casting metal. The sand is reused many times in the plant. Spent foundry sand is molding and core sand that can no longer make molds or cores.

Green sand and chemically bonded sand

Green sand is bonded with clay, usually bentonite, plus water and additives such as carbon. Chemically bonded sand uses resin binders. Most cores are chemically bonded. The binder system affects what the spent sand contains.

Beneficial reuse

Beneficial reuse puts a waste material to productive use instead of disposing of it. In Alabama, “beneficial use” is a defined term that covers only land application of a by-product as a soil amendment or fertilizer. ADEM’s foundry waste rule and its recycling rules cover other routes.

TCLP

The Toxicity Characteristic Leaching Procedure (EPA Method 1311) measures how much of certain contaminants can leach from a sample. It is one part of deciding whether a waste is hazardous.

What’s in your spent sand?

Spent sand carries what the casting process added: binder residue, metal fines, and burnt core material. The alloy matters most. Sand from iron, steel, and aluminum foundries is the most commonly reused. Sand from leaded brass and bronze foundries is often regulated as hazardous waste.

Keep each stream separate. Baghouse dust, shotblast fines, cupola slag, broken cores, and core room sweepings need their own evaluation. Mixing them into spent sand can change how the whole load is managed. Track the alloys cast, the binder system, and any process changes.

Alabama’s foundry waste and recycling rules

Alabama’s solid waste rules are in ADEM Admin. Code Division 335-13. They define foundry waste as waste from foundry smelting and metal casting, including slag, sand, and baghouse dust (335-13-1-.03(57)). Foundry waste is one of the listed examples of special waste (335-13-1-.03(138)).

Foundry waste rule

Rule 335-13-4-.26(3) sets disposal requirements for foundry waste. It applies to foundry waste whose TCLP results are below 50 percent of each toxicity characteristic level for metals. That waste may be managed in any area except:

flood plains;
wetlands;
residential zones; or
areas less than 5 feet above the uppermost aquifer.

The rule also sets these conditions:

Site records: each foundry keeps records at the plant. They describe each site to the quarter-quarter section of a township and range, and give the volume placed at each location.
Certification: the generator certifies the waste every quarter, or sooner when a process change could significantly alter the test results. Each certification is a completed Solid/Hazardous Waste Determination Form plus a TCLP analysis for metals.
Water permits: each foundry contacts ADEM’s Water Division about general stormwater or NPDES permits.
Shared sites: waste from two or more foundries may go to one location if each foundry’s records are kept.

Foundry waste that does not meet these terms must go to an approved recycle/reuse facility, or to a permitted landfill unit approved for foundry waste. A construction/demolition-inert landfill unit may receive foundry waste that meets 335-13-4-.26(3).

Recovered materials

Under 335-13-1-.03, solid waste does not include recovered materials. Recovered materials must:

have known recycling potential and be feasible to recycle;
be diverted or removed from the solid waste stream for recycling; and
be consistently used, in substantial part, to make products that would otherwise be made from raw or virgin materials.

Recovered materials do not include materials destined for any use that constitutes disposal. At least 75 percent of the material on hand at the start of each calendar year must be recycled or transferred for recycling during that year.

Facilities that handle recovered materials register with ADEM under chapter 335-13-3. A recovered materials processing facility may not receive, store, process, or transfer recovered material until it is registered. An end-use manufacturing facility uses recovered material in place of a raw material to make a product. It must also register.

ADEM’s beneficial use rule, chapter 335-13-16, covers land application only. The by-product must replace a raw material as a soil amendment or fertilizer. It must be characterized, suit the agronomic application rate, and not be hazardous waste.

Working with ADEM

Foundry waste certification: the generator submits a completed Solid/Hazardous Waste Determination Form and a TCLP metals analysis each quarter, or sooner after a significant process change.
Recycling facilities: the receiving facility registers. A new recovered materials processing facility or end-use manufacturing facility registers at least 45 days before it receives materials.
How to register: submit Form 015 through ADEM’s online system, AEPACS. Processing facilities file the registration version. End-use manufacturers file the notification version.
Term: processing facility registrations are valid for five years. Submit renewals at least 60 days before expiration. ADEM charges no application or renewal fee.
Changes: a processing facility that accepts a new type of material submits a registration modification within 30 days of first receipt. Registrations are not transferable.
Land application: generators and distributors handling 100 dry short tons a year or more register under 335-13-16 on ADEM Form 569.
Disposal: special waste needs ADEM approval before it goes to a permitted landfill. Submit ADEM Form 300. The generator gives the landfill a copy of ADEM’s approval letter. Some waste stream approvals are valid for two years.

ADEM Materials Management Section (recycling facility questions): 334-274-4201. ADEM Environmental Services Branch (waste pre-approvals): (334) 271-7824.

Hazardous waste determination

Alabama runs its own hazardous waste rules in ADEM Admin. Code Division 335-14. Chapter 335-14-2 identifies and lists hazardous waste.

Alabama adds an approval step for disposal inside the state. Hazardous waste and special waste sent to permitted disposal facilities in Alabama need ADEM approval first, under 335-14-2-.01 and 335-13-4-.26. Generators use ADEM Form 278, or the disposal facility’s form, for hazardous waste. They use Form 300 for special waste.

Under ADEM Admin. Code r. 335-14-3-.01(2), the foundry must decide whether its spent sand is hazardous:

Make the determination at the point of generation, before mixing or dilution. Repeat it if the waste may have changed.
Check whether the waste is excluded from the hazardous waste rules.
Check whether it matches a listed hazardous waste.
Check for hazardous characteristics, including toxicity. Use knowledge of the materials and process, testing, or both. Test when knowledge alone is not enough.

Small and large quantity generators must keep records supporting the determination for at least three years after the waste was last sent for treatment, storage, or disposal.

TCLP testing and limits

Tell the lab the alloys cast, the binder system, and which streams the sample includes. Use representative samples. Agree on the sampling plan with the lab, ADEM, and the receiving site before collecting.

A waste is hazardous for toxicity if its TCLP extract meets or exceeds any limit in 40 CFR 261.24. The limits for the RCRA metals are:

TCLP regulatory levels, RCRA metals
Contaminant	EPA waste code	Limit (mg/L)
Arsenic	D004	5.0
Barium	D005	100.0
Cadmium	D006	1.0
Chromium	D007	5.0
Lead	D008	5.0
Mercury	D009	0.2
Selenium	D010	1.0
Silver	D011	5.0

Passing TCLP addresses toxicity for the substances tested. It does not approve reuse or rule out other reasons a waste may be hazardous. See material testing for sampling basics.

Under 335-13-4-.26(3), foundry waste qualifies only when its TCLP metals results are below half of each limit in the table. Test and certify every quarter, and again after any process change that could significantly alter the results.

Finding a reuse destination

EPA’s 2014 risk assessment found three uses protective of health and the environment for silica-based spent sand from iron, steel, and aluminum foundries: manufactured soil, soil-less potting media, and road subbase. EPA and USDA support those uses. The finding does not cover sand from brass or bronze foundries, olivine sand, or sand mixed with other foundry wastes such as baghouse dust or cupola slag. EPA defers to state programs, so the state rules on this page still decide each use.

ADEM decides how each material and use fits its rules. Check any destination and proposed use with ADEM before scheduling delivery.

When you talk to ADEM, describe the proposal in the terms of its rules. Will a registered end-use manufacturer use the sand in place of a raw material? Will the sand be placed under 335-13-4-.26(3), outside flood plains, wetlands, residential zones, and areas within 5 feet of the uppermost aquifer? Get the receiving site’s specifications and written acceptance. If reuse is not cleared, arrange disposal that fits the waste determination.

Worker protection

Silica: foundry sand is mostly crystalline silica. OSHA’s general industry standard, 29 CFR 1910.1053, sets a permissible exposure limit of 50 µg/m³ of respirable crystalline silica as an 8-hour average. Exposure assessment starts at the 25 µg/m³ action level.
Construction use: crews placing sand as fill or subbase fall under the construction silica standard, 29 CFR 1926.1153.
Lead: brass and bronze foundries that cast leaded alloys also follow OSHA’s lead standard, 29 CFR 1910.1025.
Dust: control dust during shakeout, storage, and loading.

Storage and records

Store spent sand on a defined pad or in bins, control dust and runoff, and keep other foundry wastes out. Registered processing facilities may not accumulate recovered material speculatively. They must recycle or transfer at least 75 percent of the material on hand at the start of each year, and keep an inventory log.

Keep the waste determination, quarterly certifications, lab reports, ADEM approvals, and the receiving site’s acceptance together. For each site used under 335-13-4-.26(3), keep the site description and the volume placed there at the plant. Registered recycling facilities keep their records for at least three years.

Before pickup

Identify the alloys cast, sand and binder systems, separate streams, monthly volume, and plant location.
Make the hazardous waste determination and complete the required tests.
Choose a destination and get its material specifications.
Confirm the route with ADEM: the foundry waste rule’s conditions, the receiving facility’s registration, or special waste approval for disposal.
Get written acceptance and arrange pickup.

Common questions

Is a passing TCLP test enough?

No. It answers a toxicity question for the substances tested. The full waste determination, ADEM’s rules, and the receiving site’s specifications still apply. The foundry waste rule also needs metals results below half of each TCLP limit.

Does EPA’s risk assessment approve our sand?

No. It supports three soil-related uses for silica-based sand from iron, steel, and aluminum foundries. ADEM’s rules still decide each use in Alabama.

How often must we certify our foundry waste?

Every quarter, or sooner when a process change could significantly alter the test results. Each certification is a Solid/Hazardous Waste Determination Form plus a TCLP metals analysis.

Can sand from several foundries go to one site?

Yes, under 335-13-4-.26(3)(e), if documentation and records are kept for each foundry.

What if our sand does not meet the 50 percent test?

It must go to an approved recycle/reuse facility, or to a permitted landfill unit approved for foundry waste.

Does the receiving facility need to register?

A recovered materials processing facility must register before it receives material. A new end-use manufacturing facility registers at least 45 days before it receives material.