Foundry Sand Reuse in Virginia | Foundry Recycling Services

Planning to reuse spent foundry sand in Virginia? This guide covers the rules that apply, the tests that decide how the sand can be managed, and what 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. Virginia calls DEQ’s case-specific approval a “beneficial use determination.”

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.

Virginia’s beneficial use rule

Virginia’s Solid Waste Management Regulations count waste from nonferrous metals manufacturing and foundries as industrial waste (9VAC20-81-10). Two provisions cover reuse.

Materials that are not solid waste

Under 9VAC20-81-95 C 5, materials are not solid waste when they are:

used or reused, or prepared for use or reuse, as an ingredient in an industrial process to make a product;
used as effective substitutes for commercial products or natural resources; or
returned to the original process that generated them.

The first two apply only when the material is not reclaimed or accumulated speculatively. Material is not accumulated speculatively when it has a feasible use and 75% of it is removed from the facility each year (9VAC20-81-10).

Landfill cover has its own provision. Solid waste may serve as alternate daily cover, or as protective material for liner or final cover systems, when DEQ approves it in writing before placement. It may also be used when the landfill’s permit specifically names it (9VAC20-81-95 C 7 g).

Beneficial use determinations

For other uses, request a case-specific determination under 9VAC20-81-97. DEQ may determine that a solid waste can be beneficially used:

in a manufacturing process to make a product; or
as an effective substitute for a commercial product.

The proposal must be a reuse rather than disposal. Sand going into a manufacturing process must not need decontamination or special handling first. DEQ may also apply other criteria it considers appropriate. The material must be managed so it does not create an open dump, hazard, or public nuisance.

DEQ may approve the request, deny it, or approve it with conditions. It also sets the point where the material stops being a solid waste. Unless DEQ decides otherwise, that point is when the sand is used to make a product or as a substitute product.

Requesting a DEQ determination

Who files: the generator or the proposed user of the material.
What to send: a description of the sand and its proposed use, and the chemical and physical characteristics of the sand and each proposed product.
Market evidence: describe how the product will be used, show it meets any industry standards for that product, or provide other proof that a market exists.
Control plan: include a solid waste control plan. It must cover the sand’s source, periodic testing, disposal of any manufacturing residue, storage type and maximum inventory, run-on and run-off control, and practices that keep the sand from dispersing.
Review: DEQ decides in writing within 90 days after it receives complete information. It may waive some information depending on the use.
Changing the end point: you may ask DEQ to set the point where the sand stops being solid waste elsewhere. Show there is little potential for improper disposal or harm from handling, transport, or storage.
After approval: DEQ may revoke a determination if the information it relied on was wrong or is no longer valid, a condition is violated, or the use becomes a public nuisance.

Virginia DEQ: (804) 698-4000. Regional solid waste contacts are listed on DEQ’s Solid Waste Permits page.

Hazardous waste determination

Virginia adopts the federal hazardous waste rules (40 CFR Parts 124, 260–266, 268, 270, 273, and 279) by reference in Part III of the Virginia Hazardous Waste Management Regulations, 9VAC20-60. It uses the July 1, 2025 edition of 40 CFR (9VAC20-60-18).

Virginia adds generator rules in 9VAC20-60-262. Large quantity generators must notify DEQ when they set up each 90-day accumulation area, and pay an annual fee. A very small quantity generator may send hazardous waste to a solid waste facility only in full compliance with the Solid Waste Management Regulations, 9VAC20-81.

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.

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, DEQ, 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.

A beneficial use request must report the chemical and physical characteristics of the sand and each proposed product. Its control plan must include periodic testing to confirm the product’s composition has not changed significantly.

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.

DEQ decides beneficial use case by case. Check any destination and proposed use with DEQ before scheduling delivery.

When you talk to DEQ, describe the proposal in the terms of 9VAC20-81-95 C 5 or 9VAC20-81-97. Is the sand an ingredient in a product, such as concrete, or a substitute for a commercial product or natural resource? For landfill cover, confirm the landfill has DEQ’s written approval or permit language for the use. 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.

Virginia Occupational Safety and Health (VOSH) runs Virginia’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. A beneficial use control plan must name the storage type and hold no more than 90 days of inventory before use. It must also control run-on and run-off at storage areas.

Sand claimed under the 9VAC20-81-95 C 5 exclusion must not be accumulated speculatively. Plan volumes so at least 75% of accumulated sand leaves the facility each year.

Keep the waste determination, lab reports, DEQ determinations, 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 use fits 9VAC20-81-95, or request a DEQ beneficial use determination 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, DEQ 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. DEQ still decides each use in Virginia.

Who can request a determination?

The generator or the proposed user of the material. FRS can help gather the material information.

Can we use another foundry’s determination?

Check with DEQ first. Each determination is case-specific and rests on the information submitted for that waste and use. DEQ may revoke a determination when that information is no longer valid.

How long can spent sand be stored before use?

A beneficial use control plan limits the maximum inventory to 90 days before use.

Can a landfill use spent sand as cover?

Yes, when DEQ approves it in writing before placement, or when the landfill’s permit specifically names it as alternate daily cover or protective material.