Foundry Sand Reuse in Pennsylvania | Foundry Recycling Services

Planning to reuse spent foundry sand in Pennsylvania? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what DEP 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 Pennsylvania, DEP authorizes beneficial use of residual waste mainly through general permits. Foundry sand used under a general permit’s terms and conditions stops being a 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.

Pennsylvania’s foundry waste general permit

Pennsylvania regulates beneficial use of residual waste in 25 Pa. Code Chapter 287. Under Subchapter H, DEP issues general permits for categories of beneficial use.

General Permit WMGR019

WMGR019, Beneficial Use of Foundry Waste, was issued November 2, 2017, and expires November 2, 2027. It covers:

waste foundry sand from ferrous and nonferrous casting foundries;
system dust from ferrous metal casting foundries; and
slag and refractories from ferrous metal casting foundries.

The sand must come from clay-bonded molds, or from foundries using one of the listed binder systems in molds or cores. The list covers phenolic urethanes, phenolic esters, phenolic hotbox, phenolic nobake, furan nobake, furan warmbox, furan SO2, alkyd urethane, alkyd oil-based core oil, and epoxy SO2.

WMGR019 allows four uses:

roadway construction material, meeting PennDOT Publication 408 specifications;
a component or ingredient in concrete or asphalt products;
a soil additive or soil substitute; and
non-roadway construction.

Non-roadway, soil, and concrete or asphalt uses must meet the applicable ASTM or other national, state, or industry standard.

Placement conditions

Cover: for construction material at athletic fields and buildings, pipe bedding, trench backfill, and tank or petroleum-soil excavations, pave the sand or cover it with at least six inches of vegetative soil or a structure. Unpaved parking lots need six inches of stone or other non-waste aggregate. Embankments need six inches of soil or non-waste aggregate.
Setbacks: keep the sand out of contact with surface water or groundwater. Do not use it within 100 feet of a perennial stream, or within 300 feet of an exceptional wetland or a water source.
Fill: do not use it as valley fill, to fill mine pits, or to grade an area. The exception is embankment fill where construction starts within three months. On multi-phase projects, cover all sand within 60 days after fill placement is complete.
Soil use: do not use the sand as a soil additive or substitute where the soil’s organic carbon is below 0.25 percent before blending.
No mixing: do not mix the sand with hazardous, municipal, special handling, or other residual waste unless DEP approves in writing.

The sand stops being a waste when it meets the permit’s chemical limits and is sold, traded, or given away for a listed use. The use must also follow Appendix A, Acceptable Uses and Restrictions. Sand stored over one year, or accumulated speculatively at the foundry, does not qualify.

Coproducts

Under § 287.8, a material that qualifies as a coproduct is not regulated as a waste. The person making the coproduct determination must show that it presents no greater threat than the product or raw material it replaces.

Applying to DEP

Who files: a person or municipality that will operate under WMGR019 must get a determination of applicability (DOA) before starting. People who only receive or use the sand follow Appendix A instead of filing.
Where: apply to the DEP regional office for your county, on DEP forms. The permit lists the regional offices.
Fee: a $500 nonrefundable fee comes with each DOA application (25 Pa. Code § 287.642).
Local copies: send a copy of the application to the host municipality, the county, the county planning agency, and any county health department when you file.
Review: DEP publishes notice in the Pennsylvania Bulletin. It decides within 60 days of the notice, or 120 days for construction materials with a 60-day comment period. The clock stops while DEP waits for requested corrections.
Start date: no activity may start until DEP approves it in writing.
Permit duties: keep general liability insurance under Chapter 287, Subchapter E. Keep a Preparedness, Prevention, and Contingency plan at the foundry and update it every five years.
Renewal: to keep operating after the expiration date, file a complete renewal application at least 180 days before it. Coverage continues while DEP processes a timely, complete renewal.
After approval: DEP may modify, suspend, or revoke coverage to prevent harm, or require an individual permit.

Hazardous waste determination

Pennsylvania adopts the federal hazardous waste rules by reference. § 261a.1 adopts 40 CFR Part 261, and § 262a.10 adopts Part 262.

A generator’s finding that a waste is not hazardous does not stop DEP from finding it hazardous (§ 262a.11). WMGR019 bars mixing foundry waste with hazardous waste.

Under 40 CFR 262.11, 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.

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, DEP, 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.

WMGR019 requires a Pennsylvania-accredited lab and samples taken where the sand leaves the foundry, before storage. Choose one of three options in Table 1 (soil and construction uses) or Table 2 (concrete and asphalt). Options 1 and 2 need at least four feet of attenuating soil above the water table or bedrock. Options 2 and 3 add leach limits, tested by TCLP or SPLP. Compliance is based on the 90 percent upper confidence level for each metal.

Test before first use and then every year. After a passing initial analysis, the generator may instead certify each year that results stay at or below 65 percent of the limits, for up to five years. Reanalyze before use when the binder, coatings, or metals cast change.

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.

Under WMGR019, sand that meets the permit limits can go to roadway construction, concrete or asphalt products, soil additives or substitutes, and non-roadway construction. Give each user a copy of Appendix A. Record the name, address, and intended use of each person who receives the sand.

DEP’s list of general permits also includes manufactured soil permits, such as WMGR046 and WMGR103, that name WMGR019 foundry sand as an input. Check that the processor holds that coverage. 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 WMGR019, store generated sand no more than one year. At any one time, store no more than the amount in the approved application. Divert storm water from storage areas, and inspect each storage area daily.

Keep the waste determination, lab reports, DEP approvals, and the receiving site’s acceptance together. WMGR019 requires analytical and waste records for at least five years. Track tonnage generated and stored each year. File an annual report with the regional office by March 1. Notify DEP at least 15 working days before using sand from a new source. 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 WMGR019 tests for the planned use.
Choose a destination and get its material specifications.
Get the DEP determination of applicability under WMGR019, and give the user Appendix A.
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, the WMGR019 limits, 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. DEP still decides each use in Pennsylvania.

Does WMGR019 cover nonferrous sand?

Yes, if the sand meets the permit’s binder, testing, and use conditions. Dust, slag, and refractories are covered only from ferrous foundries.

Does the receiving site need its own DOA?

No. People who receive or use the sand follow Appendix A instead of filing. The foundry or other operator needs the DOA.

How long can spent sand be stored?

No more than one year, unless DEP approves otherwise in writing. Sand held longer stays a waste.

When do we need to test again?

Every year, or by annual certification for up to five years when results stay at or below 65 percent of the limits. Reanalyze when binders, coatings, or metals change.