Foundry Sand Reuse in Utah | Foundry Recycling Services

Planning to reuse spent foundry sand in Utah? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what Utah DEQ 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. Utah regulates recycling and use of solid waste on the land under Rule R315-312. The Division of Waste Management and Radiation Control (DWMRC) runs the program.

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.

Utah’s recycling and land use rules

Utah’s rules name foundries directly. Under R315-301-2, industrial solid waste includes nonhazardous waste from iron and steel manufacturing and from nonferrous metals manufacturing or foundry industries.

Utah requires Director approval to own, build, change, or run a facility or site that transfers, treats, or disposes of nonhazardous solid waste (Utah Code § 19-6-108). DWMRC gives approval as a permit or a letter of approval, unless the rules exempt the activity.

Rule R315-312 sets standards for any facility that recycles or uses solid waste on the land. That includes piling waste for recycling or use. It does not apply to recycling done only in containers, tanks, vessels, or enclosed buildings. It does not apply to hazardous waste.

Under R315-312-2, a recycling facility must:

meet the general facility requirements of R315-302-2;
submit a general plan of operation, and any other information the Director requests, before recycling begins;
certify by March 1 each year that it operated under that plan during the past year; and
provide financial assurance for cleanup and closure if the Director requires it.

Outdoor piles have a limit. Storage counts as disposal if at least half the material on hand at the start of a year is not shown recycled by year end. That applies when any material has also been on site more than two years, unless the Director approves a longer period. Storage also counts as disposal if water, air, or land contamination has occurred or is likely. The Director may then require a disposal facility permit.

Utah defines recycling as extracting valuable materials from the waste stream and turning them into usable materials with a demonstrated or potential market (R315-301-2). Recycling does not include making so much material that no market exists for it.

Applying to DWMRC

Who files: the person who owns or operates the receiving facility or site.
How: use the application checklist for the facility type. Submit it through DEQ’s Community Portal. New applicants register an account and create the facility first.
Review: DWMRC checks the application for completeness, then does a full technical review. It sends a draft permit for your review.
Public notice: when the action requires it, the draft permit has a 45-day public comment period. The Division Director makes the final decision.
Before you apply: you can ask DWMRC for a preapplication meeting.
After approval: recycling facilities certify by March 1 each year that they followed their plan of operation.

DWMRC: (801) 536-0200. Ask for the Solid Waste Section.

Hazardous waste determination

Utah writes the federal hazardous waste rules into its own code, Rules R315-260 through R315-273, numbered to match 40 CFR.

Utah’s solid waste rules also reach very small quantity generator hazardous waste. When an industrial facility generates it, R315-301-2 treats it as industrial solid waste.

Under Utah Admin. Code R315-262-11, 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.

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, DWMRC, 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.

The Director may ask a recycling facility for more information before it starts operating (R315-312-2(1)).

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.

DWMRC reviews each facility’s approval. Check any destination and proposed use with DWMRC before scheduling delivery.

Review the receiving facility’s approval and the waste types it accepts. DEQ’s facility map shows permitted sites. 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.

Utah Occupational Safety and Health Division runs Utah’s OSHA-approved State Plan. For most employers, its standards apply in place of federal OSHA and must be at least as effective.

Storage and records

Store spent sand on a defined pad or in bins, control dust and runoff, and keep other foundry wastes out. Plan outdoor piles so at least half the sand on hand each year is recycled by year end. Do not keep sand on site more than two years without Director approval.

Keep the waste determination, lab reports, DWMRC approvals, and the receiving site’s acceptance together. Record tonnage shipped, dates, and destinations. 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 destination has a DWMRC approval or plan of operation that covers the 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, DWMRC’s requirements, 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. DWMRC still decides each use in Utah.

Does a recycler of spent sand need approval?

A facility that recycles or uses solid waste on the land must meet R315-312. It must submit a plan of operation before it starts. Recycling done only in containers, tanks, vessels, or enclosed buildings falls outside R315-312.

How long can spent sand sit in outdoor piles?

Storage counts as disposal if at least half the material on hand at the start of a year is not recycled by year end. That applies once any material is more than two years old. The Director may approve a longer period.

Is there a yearly filing?

Yes. Each recycling facility under R315-312 certifies by March 1 that it ran under its plan of operation during the past year.

When do we need to test again?

Repeat the determination when the waste may have changed, such as a new alloy, binder, or process. Follow any conditions in the facility’s approval.