Foundry Sand Reuse in Ohio | Foundry Recycling Services

Planning to reuse spent foundry sand in Ohio? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what Ohio 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. Ohio calls a waste with properties needed or preferred for beneficial use a “beneficial use byproduct.” Once it is managed and used under OAC Chapter 3745-599, the used byproduct is not a solid waste.

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.

Ohio’s beneficial use rules

Ohio’s beneficial use rules are OAC Chapter 3745-599. No one may beneficially use a byproduct except as the chapter allows. Spent foundry sand has three routes.

Construction material ingredient

Under OAC 3745-599-10, a byproduct may be an ingredient in asphalt concrete, cement concrete, chip and seal pavement, controlled low-strength material, grout, glass, or masonry units. No permit is needed when:

the plant making the material has the matching NAICS or SIC activity code;
the byproduct is legitimately managed under OAC 3745-599-35; and
the finished material meets generally accepted industry specifications.

Foundry sand general permits

Ohio EPA’s guidance describes two general beneficial use permits for foundry sand:

BUGPFS01: foundry sand as an ingredient in soil blends, soil-less potting media, and bioretention media. The finished blend may hold no more than 50 percent foundry sand by volume.
BUGPFS02: foundry sand as a component in structural fill and as pipe bedding.

Only foundry sand that meets all of these criteria is eligible:

it is silica sand and binders from molds and cores at foundries casting iron (gray and ductile), steel, or aluminum;
it can no longer be reused to cast products, or it exceeds the sand system’s storage capacity;
it meets the permit’s Table 1 constituent limits; and
it is not a hazardous waste under Ohio law.

Store sand at least 300 feet from public water system wells, private wells, and surface waters used for drinking water or livestock. Place it on land at least 300 feet from public water system wells and those surface waters, and at least 33 feet from other surface waters of the state. Do not store sand over or within a sensitive ground water area. Control dust during storage, blending, and use.

Individual permits

Any use outside a rule or general permit needs an individual beneficial use permit. If Ohio EPA denies general permit coverage, you may apply for one.

Stockpiles have a limit. Under OAC 3745-599-35, store the byproduct as a valuable commodity and prevent releases. It must have a feasible use, and you must not accumulate it speculatively. Follow the quantities and time frames in your permit. If the permit sets none, Ohio EPA may ask you to show that at least 75 percent of the byproduct on hand on January 1 was used or transferred for use that year.

Applying to Ohio EPA

Who files: for the foundry sand general permits, the foundry, a third party such as a distributor or soil blender, or the end user. A foundry with coverage can distribute sand to a third party, who must follow the permit conditions.
How: file a notice of intent on Ohio EPA forms, with a $200 nonrefundable fee. List the permit number, the generator and each distributor, and each use and storage location.
Package: include proof that the sand meets the eligibility criteria and is not hazardous waste. Add the sampling and analysis plan, the results, and a statistical evaluation.
More than one foundry: one coverage can include several foundries for the same $200 fee. Submit a notice of intent form and sampling results for each foundry.
Timing: Ohio EPA’s guidance asks you to apply at least two months before you plan to use the sand. A complete package can get a coverage letter within about a month.
Start date: you may not begin until Ohio EPA issues a written notification or order authorizing coverage.
Term: BUGPFS01 and BUGPFS02 took effect March 31, 2022 and expire March 31, 2027. Coverage ends at midnight on that date. If the permit is renewed, file a renewal notice of intent within 45 days of its effective date to keep temporary coverage (OAC 3745-599-220(G)).
Individual permit: apply on Ohio EPA forms, with a $350 nonrefundable fee. The permit lasts five years unless it states otherwise. Apply for renewal at least 180 days before it expires.
After approval: coverage cannot be transferred. Ohio EPA may revoke coverage for violations, harm, or information that is wrong or no longer valid.

Ohio EPA Division of Materials and Waste Management, beneficial use unit: (614) 644-2621. Forms are on the Beneficial Use Program page.

Hazardous waste determination

Ohio’s hazardous waste rules are written into the Ohio Administrative Code. Its toxicity characteristic is OAC 3745-51-24, with the same metal limits shown below.

Hazardous waste cannot be managed under Ohio’s beneficial use rules (OAC 3745-599-05). Before applying for a beneficial use permit, show that the sand is not hazardous waste. For the foundry sand general permits, Ohio EPA recommends generator knowledge, such as a process description, input materials, and safety data sheets. TCLP data also works.

Under OAC 3745-52-11, 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, Ohio 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:

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 both foundry sand general permits, the 95 percent upper confidence limit of the mean must not exceed the Table 1 totals limits for nine metals, such as lead at 300 mg/kg. BUGPFS02 adds leaching limits, tested by TCLP or SPLP (Method 1312). Ohio EPA’s guidance says TCLP is not needed for a RCRA metal whose total is below 20 times its TCLP limit.

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.

Ohio’s pre-set routes for foundry sand are:

an ingredient in asphalt concrete, cement concrete, chip and seal, controlled low-strength material, grout, glass, or masonry units, under OAC 3745-599-10;
soil blends, soil-less potting media, and bioretention media, under BUGPFS01 coverage; and
structural fill and pipe bedding, under BUGPFS02 coverage.

Use under a general permit is allowed only at locations the permit or Ohio EPA’s written authorization names. Ohio EPA may deny coverage near drinking water wells and source protection areas, in flood plains, and in other sensitive locations. 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. Under the foundry sand general permits, divert storm water away from storage areas. Send Ohio EPA an aerial map of storage locations within 30 days of coverage. By April 1 each year, store no more than four times the sand used the year before.

Keep the waste determination, lab reports, Ohio EPA approvals, and the receiving site’s acceptance together. General permit holders keep a monthly log of tonnage received and used, each generator’s details, storage and use locations, and all lab data for at least five years. File an annual report every year, even if no sand was used. Keep determination 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 use fits OAC 3745-599-10, or get written general permit coverage or an individual permit 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, Ohio EPA 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. Ohio EPA still decides each use in Ohio.

Can we use another company’s coverage?

Not by transfer. Coverage under a general permit cannot be transferred. A soil blender’s coverage can include your foundry, but only with a notice of intent form and sampling results for your sand.

Does a concrete or asphalt plant need a permit to use our sand?

Not if the use meets every condition in OAC 3745-599-10. Storage before use must still meet the legitimacy rules in OAC 3745-599-35.

Can brass or bronze foundry sand use the general permits?

No. Only sand from iron, steel, and aluminum foundries is eligible. Other sand needs an individual beneficial use permit, or disposal that fits the waste determination.

How long can spent sand be stockpiled?

Under the foundry sand general permits, by April 1 each year you may store no more than four times the sand used the previous year.

When do we need to test again?

Tell Ohio EPA before the generating process or input materials change. If the sand has a material change or no longer meets the permit, stop using it and notify Ohio EPA within three days.