Foundry Sand Reuse in Massachusetts

Planning to reuse spent foundry sand in Massachusetts? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what MassDEP 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 Massachusetts, MassDEP decides through a beneficial use determination (BUD). Material used under a BUD is called a secondary material.

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.

MassDEP’s beneficial use rule

Massachusetts’ beneficial use rule is 310 CMR 19.060. The applicant must show MassDEP that the use is beneficial and poses an insignificant potential hazard to public health, safety, or the environment. Each proposal fits one of four categories:

1. Commercial products (SW 39): the sand goes into a product, or is used as one, that meets industry specifications and stays controlled through its life. Products applied to the land do not fit this category.
2. Regulated systems (SW 40): the sand is used at a facility that MassDEP already permits, approves, or orders.
3. Restricted applications (SW 41): the use relies on risk management, such as engineering controls or use limits.
4. Unrestricted applications (SW 42): the use does not limit exposure. These proposals get the most comprehensive risk review.

A BUD takes the sand out of solid waste rules only while it is used as the BUD allows. MassDEP can also issue general BUDs for a specific use. Anyone may follow a general BUD if they meet all of its conditions.

Sand that replaces a virgin material in manufacturing must meet that material’s industry specifications, or let the product meet its performance specifications. Sand used as a product must meet that product’s accepted specifications.

Processing has a limit. If MassDEP finds that the processing needed for reuse is a solid waste processing activity, the solid waste facility rules apply to it. Not sure the rule applies to your project? Ask MassDEP for a determination of applicability. MassDEP issues it within 45 days of receiving the request.

Applying to MassDEP

• Who files: any individual, business, or organization that wants to beneficially use the material. The company’s responsible official must create an ePLACE account and submit the application.
• Consult first: contact the MassDEP regional office for a pre-application consultation. If you apply without one, MassDEP may require one before it finds the application complete.
• How: file online in the EEA ePLACE portal. Typical attachments are the lab analysis, a narrative report, best management practices for collection, transport, and use, and the application form signed and certified by a professional engineer.
• Scope: each application covers one material type, or one material plus one “other” material. Pick the regional office for a single location or community, or pick “Statewide.”
• Fees: $2,375 for SW 39 or SW 40 and $4,455 for SW 41. SW 42 fees are negotiated as an individual project. An amendment (SW 44) is $1,065. Review time starts once the fee is paid.
• Local notice: send a copy to the local board of health when the use is limited to a specific location. MassDEP takes comments for at least 21 days before a final decision.
• After approval: keep records and file the reports your BUD requires. To change an approved BUD, use the “Amend” link on its ePLACE record.

MassDEP solid waste staff work out of regional offices. Find your regional office.

Hazardous waste determination

Massachusetts hazardous waste rules are in 310 CMR 30.000, the Massachusetts Hazardous Waste Regulations.

The state lists include Massachusetts-only waste codes. For example, wastes with polychlorinated biphenyls (PCBs) at 50 ppm or more are hazardous waste MA02 under 310 CMR 30.131.

Under 310 CMR 30.302, the foundry must decide whether its spent sand is hazardous:

1. Check whether the waste is excluded from the hazardous waste rules.
2. Check whether it matches a listed hazardous waste.
3. Check for hazardous characteristics, including toxicity. Test the waste, or apply knowledge of the materials and processes used.

Massachusetts requires generators to keep determination records for at least 3 years.

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, MassDEP, 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.

For a BUD, MassDEP requires data from a certified laboratory and a statistically valid sampling plan consistent with EPA SW-846. The plan covers all hazardous materials that may reasonably be present, including critical contaminants of concern.

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.

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

When you talk to MassDEP, describe the proposal using the four categories in 310 CMR 19.060. For example, will the sand go into a commercial product such as concrete, or into a use where people could contact it? 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.

Massachusetts Department of Labor Standards (DLS) covers state and local government workers in Massachusetts. 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. A BUD application must state the storage needed to keep enough inventory for market demand. Do not handle or use the sand in a way that turns it back into a solid waste.

Keep the waste determination, lab reports, MassDEP approvals, and the receiving site’s acceptance together. Record tonnage shipped, dates, and destinations. BUD reports cover the quantity received or distributed, its sources, and any required test results.

Before pickup

1. Identify the alloys cast, sand and binder systems, separate streams, monthly volume, and plant location.
2. Make the hazardous waste determination and complete the required tests.
3. Choose a destination and get its material specifications.
4. Hold the MassDEP pre-application consultation, then file or confirm the BUD for that sand and use.
5. Get written acceptance and arrange pickup.

Common questions

Rules and guidance

• MassDEP: SW 39–42 & 44 Beneficial Use Determination or Modification
• MassDEP: Instructions for SW 39–42 Beneficial Use Determinations
• 310 CMR 19.060: Beneficial Use of Solid Waste
• 310 CMR 19.000: Solid Waste Facility Regulations
• MassDEP: Permit Application Timelines and Fees Schedule
• 310 CMR 30.000: Massachusetts Hazardous Waste Regulations
• 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
• Massachusetts Department of Labor Standards (DLS)