Foundry Sand Reuse in Illinois

Planning to reuse spent foundry sand in Illinois? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what Illinois EPA 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. Illinois uses two terms. Part 817 sorts steel and foundry wastes into classes, and the cleanest class is “beneficially usable waste.” Illinois EPA also issues beneficial use determinations (BUDs), its written opinion that a material is not a waste when used in a specific way.

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.

Illinois’s foundry sand rules

Illinois has rules written for foundry sand in 35 Ill. Adm. Code Part 817, Requirements for New Steel and Foundry Industry Wastes Landfills. Part 817 covers non-putrescible wastes from steel and foundry processes under SIC Codes 331 and 332, except SIC 3313. It also covers foundry processes at businesses whose primary SIC Code is outside 332 (Section 817.101(a)).

Uses outside Part 817

Section 817.101 sets three exclusions that matter for foundry sand:

1. Demonstrated beneficial use: Part 817 does not apply to the otherwise lawful use of foundry sand shown suitable for beneficial use under Section 817.105. That includes use as a base for road building. It does not include land reclamation, except as subsection (e) allows (817.101(d)).
2. Land reclamation: Illinois EPA may approve foundry sand for land reclamation. The owner or operator must show the use will not cause an exceedance of the groundwater quality standards in 35 Ill. Adm. Code 620 (817.101(e)).
3. Product ingredient: Part 817 does not apply to the use or reuse of foundry sand as an ingredient in an industrial process to make a product (817.101(f)).

Leach classes

Part 817 classifies each waste by its leaching potential (Section 817.105). The four classes are beneficially usable, potentially usable, low risk, and chemical waste. The leach test is in Section 817.103. Section 817.106 sets a maximum allowable leaching concentration (MALC) for each class. Waste that exceeds the low risk MALCs is regulated as chemical waste under 35 Ill. Adm. Code 811, Subpart C.

Section 817.106 also sets limits for benzene, toluene, xylenes, vinyl chloride, and other volatile organic compounds. On application, Illinois EPA may allow a secondary standard to be exceeded. The applicant must show, using Section 817.413, that groundwater standards will still be met.

Beneficially usable waste rules

Subpart B applies to steel and foundry wastes that meet the beneficially usable MALCs and are not excluded by Section 817.101 (Section 817.201). Its conditions are:

1. The waste may only be used as a substitute for commercially available materials, including soil used for land reclamation. Open dumps of beneficial waste are prohibited (817.202(a)).
2. Storage piles must not cause a dust or runoff nuisance. Access to the storage area must be restricted at all times (817.202(b)–(c)).
3. The generator certifies that waste sent to an offsite beneficial use meets the Subpart A requirements. A copy of the certification goes with the bill of lading for each shipment (817.203(a)).
4. The generator sends Illinois EPA a notice for each new recipient and each new use location (817.203(b)).
5. A storage pile must be closed as a landfill unless waste was added or removed within the past year (817.204).

Beneficial use determinations

Illinois EPA also issues BUDs under 415 ILCS 5/22.54 of the Illinois Environmental Protection Act. Section 22.54(h) sets two rules for foundry sand. Sand classified as beneficially usable and used under the Part 817 rules does not need a BUD. No one may use foundry sand for land reclamation without a BUD for that use. The application asks whether the material is a raw material or ingredient, used directly as a product, or a catalyst or carrier. A BUD lasts no more than five years. BUDs are limited to certain non-hazardous waste. Ask the Bureau of Land which route fits your sand and use.

Notices and applications

• Part 817 notice: the generator files it with Illinois EPA for each new recipient and each new use location (817.203(b)).
• Notice content: describe the generating process and the waste’s size, shape, form, particle size, and volume. Include the Section 817.103 leach results and a physical analysis covering moisture, ignitability, corrosivity, solubility, and reactivity.
• Use details: add groundwater monitoring data, if available. Describe the use and the site, including location, special handling, and an estimated usage timetable. Show that handling will not cause a release that exceeds Board standards or harms health or the environment.
• Land reclamation: get a BUD for that use under 415 ILCS 5/22.54(h). Part 817 also requires a groundwater demonstration under 817.101(e).
• BUD form: file Form LPC-PA27 with an original and three copies. Signatures must be original; stamps, electronic copies, and faxes are not accepted. Illinois EPA rejects incomplete applications.
• Who signs a BUD: the person who will use the material, or process it into a product sold to the public. The generator may file if it shows enough control over the use.
• BUD affidavits: the generator certifies how the material is generated. The end user certifies how it will store and use the material. Any marketer or other intermediate handler certifies its part.
• BUD content: compare the material with the virgin material it replaces, and identify any hazardous constituents in 35 Ill. Adm. Code 721 Appendix H. For land uses, discuss site geology and the potential for constituents to reach groundwater. Show volumes, market demand, and short storage times.

Illinois EPA Bureau of Land, Permit Section: (217) 524-3301.

Hazardous waste determination

Illinois makes the federal hazardous waste rules part of its own rules in 35 Ill. Adm. Code 700–739. 35 Ill. Adm. Code 721 identifies hazardous waste.

Illinois also regulates special waste, which includes hazardous waste and industrial process waste generated by industry. Each generator must decide whether its waste is special waste (35 Ill. Adm. Code 808.121). Special waste delivered to a transporter needs a manifest and a permitted special waste hauler, with listed exceptions. In some cases the generator can certify that an industrial process waste is not special waste.

Under 35 Ill. Adm. Code 722.111, the foundry must decide whether its spent sand is hazardous:

1. Make the determination at the point of generation, before mixing or dilution. Repeat it if the waste may have changed.
2. Check whether the waste is excluded from the hazardous waste rules.
3. Check whether it matches a listed hazardous waste.
4. 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, Illinois EPA, 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:

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.

Part 817 classes use a different leach test: ASTM D3987-85, on samples taken by ASTM D2234-76 (817.103). Test each waste stream every year, and again after a raw material or process change that could change its classification (817.104).

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.

Part 817 names two uses. It excludes sand shown suitable for beneficial use under Section 817.105 when used as a base for road building. It also excludes sand used as an ingredient in an industrial process to make a product. Land reclamation needs a BUD and Illinois EPA approval first. Beneficially usable waste may only replace commercially available materials, with the generator’s certification and notice.

Illinois EPA decides other uses case by case. Check any destination and proposed use with Illinois EPA before scheduling delivery. Get the receiving site’s specifications and written acceptance. If reuse is not cleared, arrange disposal that fits the hazardous and special waste determinations.

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.

Illinois OSHA covers state and local government workers in Illinois. Federal OSHA covers private employers.

Storage and records

Store spent sand on a defined pad or in bins, control dust and runoff, and keep other foundry wastes out. Restrict access to beneficially usable waste storage at all times (817.202). Move material in or out of each pile at least once a year. Otherwise the pile must be closed as a landfill. Illinois EPA may grant up to a six-month extension if you prove a specific market, such as a sales contract (817.204).

Keep the annual leach results, the generator certifications, the Part 817 notices, any BUD, and the receiving site’s acceptance together. Attach a copy of the certification to the bill of lading for each shipment. Record tonnage shipped, dates, and destinations. Keep determination records for at least three years.

Before pickup

1. Identify the alloys cast, sand and binder systems, separate streams, monthly volume, and plant location.
2. Make the hazardous and special waste determinations and run the Part 817 leach test.
3. Choose a destination and get its material specifications.
4. Send the Part 817 notice for a new recipient or location, or get the Illinois EPA approval or BUD the use needs.
5. Get written acceptance, attach the certification to the bill of lading, and arrange pickup.

Common questions

Rules and guidance

• 35 Ill. Adm. Code 817: Requirements for New Steel and Foundry Industry Wastes Landfills
• 35 Ill. Adm. Code 817.101: Scope and applicability
• 35 Ill. Adm. Code 817.106: Waste classification limits
• 35 Ill. Adm. Code 817.203: Notification
• 415 ILCS 5/22.54: Beneficial use determinations
• Illinois EPA: Beneficial Use Determinations
• Form LPC-PA27: Application to Request a Beneficial Use Determination
• Illinois Environmental Protection Act (415 ILCS 5)
• Illinois EPA: Does My Business Need a Land Pollution Control Permit?
• 35 Ill. Adm. Code 721: Identification and Listing of Hazardous Waste
• 35 Ill. Adm. Code 808.121: Generator obligations
• 40 CFR 262.11: Hazardous waste determination
• 40 CFR 261.24: Toxicity characteristic
• EPA Method 1311: TCLP
• EPA: Beneficial Uses of Spent Foundry Sands
• EPA: Risk Assessment of Spent Foundry Sands in Soil-Related Applications
• 29 CFR 1910.1053: Respirable crystalline silica
• 29 CFR 1926.1153: Respirable crystalline silica in construction
• Illinois OSHA