Foundry Sand Reuse in Kansas | Foundry Recycling Services

Planning to reuse spent foundry sand in Kansas? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what KDHE 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. Kansas calls this beneficial use. KDHE reviews each proposal through its application for beneficial use of industrial byproducts without a permit.

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.

Kansas’s beneficial use rules

Kansas’s solid waste law, K.S.A. 65-3402, sets two key definitions:

Recyclables are materials used or reused as an ingredient in an industrial process to make a product, or as an effective substitute for a commercial product.
Industrial waste is solid waste from manufacturing, commercial, and industrial processes. Material beneficially used in a way that meets the definition of recyclables is not industrial waste.

K.S.A. 65-3409(a)(1)(A) bans open dumping. It still allows solid waste to be used in processing or manufacturing other products. The use must not create a public nuisance or harm public health.

KDHE reviews these uses through form SWP910, its application for beneficial use of industrial byproducts without a permit. KDHE authorizes a use without a permit only when the project shows that:

the byproduct is not a solid waste; and
the proposed use is not a disposal activity.

KDHE guidance SW-2020-G1 adds two criteria for fill. The fill must be part of a larger engineering project, such as mine stabilization or engineered embankment fill. The byproduct must also have at least one engineering property that makes it suitable. Being inert is not enough.

Stockpiles have a limit. Under KDHE Policy 2011-P3, material accumulated without the potential for use or recycling is a waste. The facility storing it then needs a solid waste processing facility permit.

Applying to KDHE

Who files: form SWP910 accepts the byproduct generator, a consultant, or the byproduct user as the applicant. It also asks who will use the byproduct if the applicant will not.
How: complete form SWP910, Application for the Beneficial Use of Industrial Byproducts Without a Permit. It is listed under Beneficial Use Determination on KDHE’s Forms for Activities Not Requiring a Permit page.
What the form covers: the generating facility, the byproduct, the process that made it, and the yearly quantity. It also covers the proposed use and locations, mixing ratio, placement method, storage or drying, and local zoning or land-use limits.
Beneficial use plan: attach a separate plan. It describes the byproduct, its preparation, the proposed use, and a contingency plan. The contingency plan covers weather limits, storage, and the disposal facility used when reuse is not possible.
Attachments: include analytical results from a Kansas certified lab and a schematic of surface water controls. Ask the Bureau of Waste Management which tests are required.
Fill projects: KDHE must approve a fill project before it starts. A fill material counts as an effective substitute for a commercial product only after KDHE approves the project in a letter.

KDHE Bureau of Waste Management: (785) 296-1600.

Hazardous waste determination

Kansas adopts the federal hazardous waste rules by reference in K.A.R. Article 28-31, with state changes. The adopted federal text is the version in effect on July 1, 2006. For example, K.A.R. 28-31-260 adopts 40 CFR Part 260, and K.A.R. 28-31-262 adopts the generator rules in Part 262.

Kansas sets its own generator categories in K.A.R. 28-31-260a. A conditionally exempt small quantity generator makes less than 55 pounds (25 kg) of hazardous waste in a month. A Kansas small quantity generator makes 55 to 220 pounds (25 to 100 kg). If you test, K.A.R. 28-31-262 requires a laboratory certified by KDHE.

Under 40 CFR 262.11, in the version Kansas adopts, the foundry must decide whether its spent sand is hazardous:

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. Test the waste, or apply knowledge of the materials and processes used.

Keep test results, waste analyses, and other determinations for at least three years after the waste was last sent for treatment, storage, or disposal (40 CFR 262.40(c)).

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, KDHE, 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.

SWP910 requires analytical results from a Kansas certified lab. KDHE decides case by case what tests a fill project needs to show the engineering property.

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.

KDHE decides reuse case by case. Check any destination and proposed use with KDHE before scheduling delivery.

When you talk to KDHE, describe the proposal using the recyclables definition in K.S.A. 65-3402. For example, is the sand an ingredient in an industrial process, or a substitute for a commercial product? For fill, name the engineering project and the property the sand adds. 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. Plan volumes so stored sand moves to its use. Under KDHE Policy 2011-P3, a storage facility must be able to show that material without obvious value is not a waste. One way is to use or transfer for recycling, over a year, at least 75% of the amount held at any one time.

Keep the waste determination, lab reports, KDHE approvals, and the receiving site’s acceptance together. Record tonnage shipped, dates, and destinations. KDHE guidance HW-2011-G1 calls for a documented determination for every waste stream. Keep it for three years after the waste last ships off-site.

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 at a KDHE-certified lab.
Choose a destination and get its material specifications.
File or confirm KDHE approval of form SWP910 and the beneficial use plan for that sand and use.
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, KDHE approval, and the receiving site’s specifications still apply.

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. KDHE still decides each use in Kansas.

Can we use another foundry’s approval?

Not for fill. KDHE must approve each fill project before it starts. The sand counts as a commercial substitute only after KDHE approves that project in a letter.

Can a broker or FRS file the request?

Form SWP910 accepts the byproduct generator, a consultant, or the byproduct user as the applicant. FRS can help gather the material information.

How long can spent sand be stockpiled?

Material held without the potential for use or recycling is a waste. KDHE Policy 2011-P3 gives one way to show stored material is not waste: use or transfer for recycling, over a year, at least 75% of the amount held at any one time.

When do we need to test again?

Each waste stream needs its own documented determination. Update it when the alloy, binder, or process changes, and follow any conditions in the KDHE approval.