BENEFICIAL REUSE OF FOUNDRY SAND:

A REVIEW OF STATE PRACTICES

 AND REGULATIONS

Sector Strategies Division

Office of Policy, Economics, and Innovation

U.S. Environmental Protection Agency

Washington, DC

In partnership with

American Foundry Society

Association of State and Territorial Solid Waste Management Officials

December 2002
The U.S. EPA’s Sector Strategies Division, Office of Policy, Economics, and Innovation, would

like to acknowledge the many people who contributed to this document. Industrial Economics,

Inc. was EPA’s principal contractor and main author. The American Foundry Society (AFS) and

Association of State and Territorial Solid Waste Management Officials (ASTSWMO) were EPA’s

partners in this project. Their members provided ideas for structure and content for the report,

and they offered valuable suggestions for improving earlier drafts. The assistance provided by

Elizabeth Olenbush of Foundry Industry Recycling Starts Today (FIRST) and Dale Thompson of

the Minnesota Pollution Control Agency were especially helpful. Amy Blankenbiller of

Waterman and Associates provided crucial input on sources for content and acted as liaison

between EPA and the foundry industry. EPA’s Office of Solid Waste as well as the U.S.

Departments of Transportation and Agriculture also assisted in preparation of the document.

For further information regarding this primer and EPA’s partnership with the metal casting

sector, please contact Jerry Newsome (202-566-2967, newsome.jerry@epa.gov) or Peter Truitt (202-

566-2970, truitt.peter@epa.gov) at the U.S. EPA, or Amy Blankenbiller (202-828-1444,

ab@wafed.com) representing the industry.
i

TABLE OF CONTENTS

CHAPTER 1: INTRODUCTION AND SUMMARY OF FINDINGS

1.0 BACKGROUND ........................................................................................................ 1

1.1 PURPOSE OF THIS REPORT................................................................................... 2

1.2 SUMMARY OF KEY FINDINGS............................................................................. 2

1.3 ORGANIZATION OF REPORT................................................................................ 5

CHAPTER 2: OVERVIEW OF FOUNDRY INDUSTRY AND SAND REUSE

2.0 THE FOUNDRY INDUSTRY ................................................................................... 6

2.1 SAND USE WITHIN FOUNDRIES.......................................................................... 6

2.2 COMPOSITION OF FOUNDRY SAND................................................................... 7

2.3 POTENTIAL CONTAMINANTS IN FOUNDRY SAND ........................................ 7

2.3.1 Metal and Other Inorganic Contaminants....................................................7

2.3.2 Organic Contaminants ................................................................................. 8

CHAPTER 3: OVERVIEW OF STATE INDUSTRIAL WASTE REUSE PROGRAMS

3.0 REGULATORY ENVIRONMENT FOR REUSE OF INDUSTRIAL WASTE..... 10

3.1 FEATURES OF INDUSTRIAL WASTE REUSE PROGRAMS............................ 11

3.1.1 Initial Sampling and Testing Requirements............................................... 12

3.1.2 Constituent Concentration Thresholds....................................................... 12

3.1.3 Waste Classification Categories ................................................................ 14

3.1.4 Authorization Process for Reuses .............................................................. 15

3.1.5 Other Common Requirements ................................................................... 17

CHAPTER 4: STATE REGULATIONS AND POLICIES ADDRESSING

 FOUNDRY SAND REUSE

4.0 TAILORED REGULATION OF SAND REUSE .................................................... 19

4.1 STATE APPROACHES TO REGULATING SAND REUSE ................................ 19

4.1.1 Addressing Different Types of Foundries and Foundry Sand ...................20

4.1.2 Combining Concentration Thresholds and Other

 Regulatory Requirements........................................................................... 20

4.1.3 Balancing Allowable Reuses and Regulatory Requirements.....................20

4.2 COMPARISON OF STATE REQUIREMENTS FOR SPECIFIC REUSES .......... 20

4.2.1 Reuse in Manufacturing Another Product ................................................. 21

4.2.2 Reuse as Structural Fill .............................................................................. 23

4.2.3 Reuse as Backfill and Pipe Bedding ..........................................................25

4.2.4 Reuse in Soil Blending, Land Applications, and Composting................... 27

CHAPTER 5: CASE STUDIES OF BENEFICIAL USES OF FOUNDRY SAND

5.0 PURPOSE OF CASE STUDIES .............................................................................. 29

5.1 OVERVIEW OF FOUNDRY SAND REUSE CASE STUDIES............................. 30

5.1.1 Soil Amendment - Ohio............................................................................. 30

5.1.2 Structural Fill - Wisconsin......................................................................... 30

5.1.3 Asphalt - Michigan .................................................................................... 30
ii

5.1.4 Parking Lot Construction - West Virginia................................................. 31

5.2 SUMMARY OF FINDINGS .................................................................................... 31

5.2.1 Differences in State Reuse Programs......................................................... 31

5.2.2 Factors Affecting the Beneficial Reuse of Foundry Sand ......................... 32

5.2.3 Further Opportunities for Foundry Sand Reuse......................................... 35

APPENDIX A: SUMMARIES OF STATE GUIDELINES AND REGULATIONS ON

REUSE OF INDUSTRIAL BY-PRODUCTS

APPENDIX B: CASE STUDIES OF BENEFICIAL USES OF FOUNDRY SAND
1

INTRODUCTION AND SUMMARY OF FINDINGS CHAPTER 1 

1.0 BACKGROUND

Every year foundries generate between nine and 13 million tons of sand that is unfit for

continued use in the mold-making process. Only a small percentage of this used foundry sand is

characterized as hazardous waste, with the overwhelming majority qualifying as non-hazardous

industrial waste. Although some sand is currently "beneficially reused" – industry experts

estimate that approximately one million tons is beneficially reused outside of the foundry –

foundries typically discard this material in municipal or private landfills.1

 Given the potential for

reusing a substantial amount of the non-hazardous sand in a variety of ways, including roadbeds,

construction fill, and cement, it is likely that much of the sand currently disposed of in landfills is

"beneficially reusable."

A variety of factors contribute to the low level of sand reuse. These factors affect each of

the stakeholders who can play a role in beneficially reusing this waste.

• For states, developing a regulatory structure that simultaneously ensures

environmental protection and encourages appropriate beneficial reuse can be

very challenging. Also, the lack of an established process for evaluating and

permitting reuses can be a significant barrier.

• Prospective end users may not know that foundry sand is reusable. They may

incorrectly assume that foundry sand may not perform properly from an

engineering standpoint, or that it may contain unacceptable concentrations of

toxic constituents.

• Finally, foundries may not be aware of the many potential uses for their sand,

or may not have considered simple operational changes that could have

dramatic effects on the characteristics of sand (e.g., waste stream segregation)

and thus enhance their ability to find alternatives to landfill disposal.

 1 Foundry sand estimates are from Dr. Paul J. Tikalsky of Pennsylvania State University, collated from

FIRST (Foundry Industry Recycling Starts Today) data.
2

1.1 PURPOSE OF THIS REPORT

The foundry industry has frequently cited the beneficial reuse of foundry sand as one of

its most important environmental issues. To address this concern, the U.S. Environmental

Protection Agency (EPA) assembled a workgroup of representatives from industry, states (the

Association of State and Territorial Solid Waste Management Officials, ASTSWMO), and the

U.S. Departments of Transportation and Agriculture. The workgroup recommended that EPA

research existing state beneficial reuse programs, conduct case studies examining "real-world"

reuses of foundry sand, conduct a scientific characterization of foundry sands, and suggest

approaches to encourage increased future reuse.

In response to the workgroup's recommendations, EPA researched regulations, statutes,

guidance documents, policies, websites, and other publicly available information regarding

beneficial reuse of foundry sand, industrial waste recycling, and solid waste designation in 18

states. These states have the largest numbers of foundries in the country and have active

industrial waste recycling programs or initiatives. EPA also conducted four case studies of

ongoing or recently completed projects involving the beneficial reuse of sand.

Additional testing data are needed to more fully characterize the composition of foundry

sand, and tests are being conducted. In the interim, this report is intended to serve as a national

reference for all stakeholders potentially involved in the beneficial reuse of foundry sand.

• For states, the document provides regulators with information to facilitate the

process of determining appropriate beneficial reuses. It is a resource for

understanding existing guidance and/or regulations developed by other states,

which can serve as a model for developing beneficial reuse policy.

• For foundries, it is a resource for: (1) understanding existing guidance and/or

regulations developed by different states; and (2) identifying reuses that are

alternatives to sand disposal and working with states to take advantage of

them.

• For potential end users, the document is a resource for exploring the

potential use of foundry sand as an alternative to virgin raw materials.

This report was prepared by the Metal Casting Industry Performance Partnership

Program, created and led by the Sector Strategies Division within EPA’s Office of Policy,

Economics, and Innovation. The program is a cooperative effort involving EPA, the American

Foundry Society, and a number of state governments. It aims to reduce pollution and increase

the reuse and recycling of used materials in the metal casting sector, including foundries.

1.2 SUMMARY OF KEY FINDINGS

EPA's research on state programs and insights gained from case studies highlight several

key findings related to sand reuse. When considered together, these findings suggest that there is

significant opportunity for expanding beneficial reuse of foundry sand:
3

• Used foundry sand is a high volume industrial waste that can be more

widely reused as an alternative to landfill disposal. A brief look at three

factors supports this finding: (1) foundries generate substantial volumes of

used sand that is non-hazardous, consistent in composition, and available in

ample supply; (2) foundry sand exhibits physical and engineering

characteristics comparable to those of virgin raw materials used in a variety of

applications, such as asphalt manufacturing, road embankment construction,

and soil amendments (see Exhibit 1-1 for a list of potential beneficial reuses);

and (3) landfill capacity should not be used for materials that can be

beneficially reused.

• Many states are receptive to recycling/reuse proposals from industry,

provided they are backed by sound science demonstrating that reuse will

not result in adverse environmental impacts. The quantity and quality of

testing and scientific data provided to the state in support of reuse proposals

are critical factors affecting the state's ability to develop protective beneficial

reuse permits, policies, and regulations. Because developing the necessary

data to support a new reuse can be extremely burdensome for an individual

foundry, efforts on the part of state agencies or trade associations to sponsor

the necessary research can significantly contribute to the expansion of reuse

opportunities.

• Simple, straightforward regulations that streamline the process for

approving reuses can enhance the opportunities for safe, beneficial reuse

of foundry sand. The key factor in increasing foundry sand reuse appears to

be the strong support and encouragement of the state regulatory agency. This

support can be seen in some states’ efforts to streamline the approval process

for reuse projects. States use a range of alternatives to simplify project

approvals, including issuing general permits that cover multiple reuse

projects, allowing certain reuse projects to proceed with only prior

notification, and providing waste exemptions for qualifying by-products.

• Cost savings is the primary motivating factor for reuse of foundry sand.

In determining whether to pursue opportunities to reuse sand, a foundry

weighs the cost of transporting sand to a landfill and tipping fees against the

costs of preparing sand for reuse, which may include segregating sand from

other by-products, and transporting it to the reuse location. End users weigh

the cost of virgin raw material against the cost of obtaining and using foundry

sand, including testing that must be performed on end products, lead time

required for project approval, and the effect on sales of a negative perception

of products containing an industrial by-product.
4

Exhibit 1-1

BENEFICIAL REUSES OF FOUNDRY SAND

Foundry sand can be suitable for a variety of beneficial reuses. Terminology for defining uses varies

across states. For the purposes of this report, EPA has developed definitions for common uses of sand in

consultation with industry experts. The following are uses of foundry sand approved in one or more

states:

Structural Fill

Foundry sand can be used as support for structures such as roadways, parking lots, buildings, and pieces

of equipment. "Encapsulated" structural fill may involve the use of a liner, cap, or cover, generally made

of a clay material, which prevents water from percolating through the foundry sand and minimizes the

potential for leaching.

Manufacturing Another Product

Foundry sand is useful as a raw material in manufacturing other products, such as controlled, low-strength

material (CLSM or flowable fill), asphalt, cement, concrete, grout, lightweight aggregate, concrete block,

bricks, roofing materials, plastics, paint, glass, ceramics, and rockwool. Specific examples of these uses

include:

• Flowable fill: Flowable fill is a liquid-like material that self-compacts and is used as a substitute

for conventional soil backfill. The product is easily transported and can be readily re-excavated.

The typical mixture contains sand, fly ash, portland cement, and water. Foundry sand can readily

be substituted for virgin sand in flowable fill mixtures.

• Cement and Concrete: Sand is a component of Portland cement and concrete. Portland cement

requires sand with a silica content of at least 80 percent, which most foundry sands meet. It also

requires certain minerals such as iron and aluminum oxides, which are found in many foundry

sands. Cement and additional sand or gravel are components of concrete, allowing further reuse

of foundry sand.

Soil Manufacturing and Amendment

Commercial soil blending operations can use foundry sand to produce horticultural soils, topsoil, potting

soil, and turf mixes. These soil products are typically mixtures of sand or gravel with peat, fertilizers,

and/or top soil. Foundry sand can also improve the performance of agricultural soils, and can be used as a

composting ingredient.

Landfill Uses

Foundry sand can be used as a cover for the working face of an active landfill, for road construction

within the active cell, or as a substitute for virgin aggregate in the construction of drainage layers for

landfill leachate collection systems.

Pipe Bedding and Backfill

Foundry sand can serve as backfill for trenches created by the installation of storm and sanitary sewer

lines.
5

• Foundry sand consolidators create economies of scale that can overcome

some of the barriers to increased beneficial sand reuse. In many cases,

foundry sand reuses involving a single foundry or end user may not be

economically or operationally feasible, particularly when transportation costs

are prohibitively expensive or when individual foundries generate relatively

small quantities of sand. "Middlemen" can make sand reuse possible through

consolidating and preparing sand from multiple foundries for reuse by

multiple end users.

• Heightened awareness among stakeholders can substantially increase the

volume of foundry sand beneficially reused. Information sharing among

federal, state, and local government agencies, foundries, and potential end

users can: (1) increase both the supply of foundry sand available as a raw

material and the demand for it as a substitute for virgin raw materials; (2)

provide state regulators with more information about the characteristics of

foundry sand, and with examples of how they can structure their programs to

encourage increased sand reuse while protecting against any potential

negative environmental impacts; (3) increase foundries’ awareness of the

opportunities for reuse; and (4) educate potential end users about the

comparability of foundry sand to virgin raw materials as an input to their

products.

1.3 ORGANIZATION OF REPORT

This report presents the results of EPA’s research into state practices and regulations

regarding the beneficial reuse of foundry sand. Chapter 2 provides a brief overview of the

foundry industry and a description of the composition of foundry sand. Chapter 3 describes the

range of approaches to regulating the reuse of non-hazardous industrial wastes across 18 states.

(Appendix A provides additional information on industrial waste programs in these states.)

Chapter 4 is a more in-depth review of the guidance and regulations developed by seven states

that specifically address beneficial reuse of foundry sand in their guidance and/or regulations.

EPA also conducted four case studies of ongoing or recently completed projects involving the

beneficial reuse of sand to identify factors that affect the potential for sand reuse. Chapter 5

includes brief descriptions of each case study, plus an overview of the findings from the case

studies. (More detailed descriptions of the case studies are included in Appendix B.)
6

OVERVIEW OF FOUNDRY INDUSTRY AND SAND REUSE CHAPTER 2

2.0 THE FOUNDRY INDUSTRY

In 2000, the domestic foundry industry reported over 27 billion dollars in sales.2 The

industry produces castings for a wide array of products ranging from engine blocks to

construction and farming equipment to golf club heads. Foundries typically utilize temporary

molds constructed of sand and other materials, and are classified as either ferrous or nonferrous, depending on the type of metals used. Ferrous foundries produce parts cast from iron

and steel. Non-ferrous foundries may use aluminum, beryllium, cobalt, copper, zinc, lead, tin,

nickel, magnesium, or titanium.

The majority of foundries are located close to their major markets, which are in large

part the industrial/automobile manufacturing belt in the central United States. Foundries in six

states – Ohio, Michigan, Illinois, Wisconsin, Pennsylvania, and California – make up over half

of all foundries in the United States.3

2.1 SAND USE WITHIN FOUNDRIES

Foundries produce ferrous and non-ferrous castings, and in the process generate large

quantities of waste sand that can no longer be used in the casting process. Non-reuseable sand

accounts for 55 to 90 percent of the total waste stream of a facility. Nationally, only two

percent of foundry sand is considered hazardous.4 The remaining 98 percent is a non-hazardous

industrial by-product that can be reused in a variety of products or disposed of in non-hazardous

landfills.

The U.S. foundry industry uses approximately 100 million tons of sand per year.

Roughly 90 percent is reused for making molds within the foundries, but 9 to 13 million tons of

 2 American Foundry Society.

3 U.S. EPA. 1998. "Sustainable Industry: Metal Casting Industry Profile." U.S. EPA Office of Policy,

Industry Sector Policy Division.

4 U.S. EPA. 1998. Metal Casting Industry Sector Notebook. U.S. EPA Office of Compliance.
7

this sand is no longer useable in the casting process. Of this sand, approximately one million

tons are recycled for other uses every year; the remaining 8 to 12 million tons are landfilled.5

Many foundries have invested in sand reclamation systems that can recover up to 95

percent of sand used in the casting process. These systems represent an important

environmental and economic opportunity for foundries, helping to control production costs and

to reduce the amount of waste for disposal. Even with this increase in sand reclamation, there is

a limit to the number of times sand can be effectively reused in the casting process, eventually

resulting in a large amount of used sand that could be beneficially reused elsewhere.

2.2 COMPOSITION OF FOUNDRY SAND

Casting processes used by foundries involve a variety of sands, inorganic and organic

binders, and other additives. They generate residues in the sand, including metals from the

castings and compounds from binders used to form the sand into molds. The presence of these

residues and the mixing of used sand with dust and other fine-grained foundry waste materials

can limit the reusability of foundry sand.

Foundries use screening systems and magnetic separators to segregate reusable sand

from other wastes and to separate particles of varying sizes. By carefully monitoring the casting

process and used sand, foundries can ensure that their sand is largely free of excess

contaminants and qualifies as a non-hazardous industrial by-product.

2.3 POTENTIAL CONTAMINANTS IN FOUNDRY SAND

Several studies have been conducted to characterize foundry sand and evaluate the likely

environmental impacts of reusing sand. These studies primarily rely on tests of the potential for

various constituents to leach from the sand, such as the Toxicity Characteristics Leaching

Procedure (TCLP), which measures constituent concentrations dissolved in an acidic solution

that has been in contact with the sand.6

2.3.1 Metal and Other Inorganic Contaminants

In general, TCLP results show that metal concentrations in foundry sand are below

regulatory thresholds, such as those specified for hazardous waste by the Resource

Conservation and Recovery Act (RCRA).7

 Many of the leachate concentrations measured were 5 Foundry sand estimates are from Dr. Paul J. Tikalsky of Pennsylvania State University, collated from

FIRST (Foundry Industry Recycling Starts Today) data.

6 The TCLP is the most commonly used leach test, however, several states use the Synthetic Precipitation

Leaching Procedure (SPLP). In addition, a number of states use other tests, such as a totals analysis, which is an

analysis of the composition of the sand itself.

7 E.S. Winkler and A.A. Bolshakov. 2000. "Characterization of Foundry Sand Waste." Chelsea Center for

Recycling and Economic Development, University of Massachusetts at Lowell.
8

lower than federal drinking water standards, indicating it is generally safe to reuse these sands.

Studies of foundry sand also indicate that metal contaminant concentrations are on the same

order of magnitude as those in virgin sand and sandy soils.8

On the other hand, mixed foundry by-products from non-ferrous foundries (which

contain a combination of sand, dusts, and slag) have occasionally been found to have metal

leachate concentrations above RCRA thresholds.9

 For example, some foundry dusts have been

found to have higher concentrations of metals relative to sand. Comparisons of the total metal

content of sand to TCLP results found no direct correlation.

2.3.2 Organic Contaminants

The binder system is the primary source of organic contaminants in sand. The primary

organic contaminants from foundry sand cores are acetone and 1,1,1-trichloroethane, and a

number of aromatic compounds, as shown in Exhibit 2-1. Green sand casting, which generally

does not involve the use of organic binders, has been shown to have lower potential for leaching

organic compounds than chemically bonded systems.10

Depending on the curing and pouring process, some of the organic binder constituents

may be altered from their original composition. The more reactive organic compounds

commonly used in binders and resins are of special concern, because they can be transformed

into new hazardous compounds under incomplete combustion conditions.11 However, testing

has not indicated that these reactive compounds are found at significant concentrations in sand.

For example, of the 45,000 compounds tested in the ground water in the vicinity of

foundry landfills in Wisconsin, none was found to be above 1 μg/L (ppb).12 Several

contaminants were found in trace quantities at less than 1 ppb in laboratory leachate tests, with

the phenolic urethane and the phenolic isocyanate binder systems contributing the highest

organic compound content, but no contaminants exceeded EPA drinking water standards. In

aluminum foundries, which cast at a lower temperature, less of the organic binder is burned off,

increasing the potential for residual organic contaminants to be present in the sand.

 8 Winkler and Bolshakov 2000.

9 Winkler and Bolshakov reviewed studies of different leachate tests, including the following: (1) field

leachate from landfills or sand reuse projects; (2) TCLP; and (3) EP [extraction procedure]. Both TCLP and EP are

acetic acid extractions, but the TCLP extraction is performed at a lower pH, which tends to lead to higher extraction

values.

10 In some cases, starches and sea coal are added to green sands, which can lead to production of polycyclic

aromatic hydrocarbons upon heating.

11 In recent years, foundries have made efforts to reduce the use of these elements in their binder systems.

12 As reported in Winkler and Bolshakov 2000.
9

Exhibit 2-1

PRIMARY ORGANIC COMPOUNDS FOUND IN FOUNDRY SAND CORES

Acetone1 Formaldehyde2

Benzene1 Isopropylbenzene1

2-chlorophenol2 1- and 2-Methylnaphthalene1,2

m/p-Cresol2 Naphthalene1

1,2-Dichlorobenzene2 Phenol2

1,4-Dichlorobenzene2 Tetrachloroethane2

Diethylbenzenes1 Toluene2

Dimethylnaphthalenes1 1,1,1-Trichloroethane1

2,4-Dimethylphenol2 1,2,4-Trimethylbenzene1

Ethylbenzene2 1,3,5-Trimethylphenol2

p-Ethyltoluene1 Xylenes1,2

Sources:

1 Winkler and Bolshakov, "Characterization of Foundry Sand Waste," October 2000. Chelsea Center for

Recycling and Economic Development, University of Massachusetts at Lowell.

2

 Michigan Department of Environmental Quality test results, Duane Roskoskey, October 2002.
10

OVERVIEW OF STATE INDUSTRIAL WASTE REUSE PROGRAMS CHAPTER 3

3.0 REGULATORY ENVIRONMENT FOR REUSE OF INDUSTRIAL WASTE

EPA estimates that 7.6 billion tons of non-hazardous industrial waste are generated and

disposed of annually in the U.S.13 Promoting recycling is a stated priority for EPA's Office of

Solid Waste and Emergency Response for Fiscal Year 2003.14 Accordingly, EPA is emphasizing

the importance of waste reduction and more efficient and sustainable use of resources. Looking

to the future, the Agency anticipates that "many materials that are now considered wastes will

instead be used to produce new materials and products. As this shift happens, it is likely that

current distinctions between wastes and materials (which are in large part regulatory in nature)

will become less meaningful. This could argue for government policies that more effectively

promote, and reduce unnecessary regulatory constraints on, more efficient use of these

materials."15 For the foundry industry, such policies would translate into the development of

regulatory approaches that encourage increased beneficial reuse of foundry sand. Although

states play a primary role in establishing industrial waste regulations and guidance, there is a role

for EPA to provide coordination and assistance at the national level to help achieve such a shift

in waste management policy.

The anticipated shift in waste and materials management, along with opportunities for

more effective regulatory approaches, suggests that the timing is well suited for stakeholders to

focus on industrial waste reuse generally, and foundry sand reuse specifically. Because the

majority of used foundry sand is considered non-hazardous industrial waste, it is important for

foundries and end users of this material to understand existing state approaches to regulating

waste reuse as they search for viable reuse opportunities. In addition, looking across different

industrial waste reuse programs can highlight regulations or requirements that are particularly

 13 U.S. EPA. http://www.epa.gov/industrialwaste/, updated 6/24/02, as viewed July 9, 2002.

14 U.S. EPA. http://www.epa.gov/swerrims/Mission.htm, as viewed July 9, 2002.

15 U.S. EPA. "Beyond RCRA: Prospects for Waste and Materials Management in the Year 2020, A Draft

White Paper," February 2001, p. 8.
11

informative, even transferable, to states wishing to refine their regulatory approaches to

encourage increased reuse of industrial by-products.

This chapter provides a framework for understanding approaches used by states to

regulate non-hazardous industrial solid waste reuse. It presents an overview of industrial waste

reuse programs in 18 different states. The criteria used in selecting these states included:

• States with the largest number of foundries (and, thus, of greatest relevance to this

effort, since they represent the greatest potential for reuse of foundry sands).

• States with active industrial waste reuse programs (although many more states than

those included in this review have active industrial waste programs).

• States that have developed guidance specific to the beneficial reuse of foundry sand

or have actively worked with the foundry industry on this issue.

This combination of criteria, along with previous knowledge of certain state programs

and suggestions from participants in the Metal Casting Industry Performance Partnership, led

EPA to focus on the states listed in Exhibit 3-1.

Exhibit 3-1

STATES SELECTED FOR REVIEW OF INDUSTRIAL

WASTE REUSE REGULATIONS

• Alabama • Maine • Pennsylvania

• California • Massachusetts • Rhode Island

• Illinois • Michigan • Tennessee

• Indiana • Minnesota • Texas

• Iowa • New York • West Virginia

• Louisiana • Ohio • Wisconsin

3.1 FEATURES OF INDUSTRIAL WASTE REUSE PROGRAMS

The underlying concept of all the state reuse programs reviewed is to ensure the

protection of human health and the environment by identifying and minimizing potential risks of

reusing industrial wastes. This goal is accomplished through one or more of the following

approaches: requiring risk assessments for each proposed reuse project; developing general

concentration thresholds (both for leachate from the industrial waste and for contaminants in the

waste itself) applicable to specific reuses; and implementing other requirements designed to

prevent an unacceptable level of risk, such as restrictions on the siting of reuse projects and

sampling and testing, notification, and reporting requirements.
12

The rules and guidance for industrial waste reuse vary significantly across the states

reviewed. Some states have a single set of requirements for all industrial by-products or wastes,

while others have developed specific regulatory requirements for individual types of industrial

wastes (e.g., foundry sand, waste tires, fly ash). Of the 18 state programs described in this

report, 11 states rely on requirements established for industrial solid wastes generally. The

remaining seven specifically address the beneficial reuse of foundry sand in their rules or

policies. (These programs are discussed in greater detail in Chapter 4.)

Exhibits 3-2 and 3-3 summarize the characteristics of state industrial waste reuse

programs. Exhibit 3-2 indicates whether the state programs reviewed are general or specific to

foundries, and focuses on their sampling requirements, constituent concentration thresholds,

waste classification categories, and authorization processes. Exhibit 3-3 presents information on

program requirements for siting and for frequency of industrial waste sampling and testing.

Detailed descriptions of the state programs are presented in Appendix A.

3.1.1 Initial Sampling and Testing Requirements

All 18 states require an initial characterization of the industrial waste demonstrating that

it qualifies as non-hazardous. This characterization typically involves a leachate test, with TCLP

being the most frequently specified test. Five of the states (Louisiana, Maine, Pennsylvania,

West Virginia, and Wisconsin) also require an analysis of the composition of the waste itself

(totals analysis). In addition, a sampling and analysis plan (SAP) consistent with EPA’s Test

Methods for Evaluating Solid Waste, SW-846, is explicitly required by five states - Indiana,

Maine, Michigan, Pennsylvania, and West Virginia - although several others require elements of

an SAP.16

3.1.2 Constituent Concentration Thresholds

As Exhibit 3-2 illustrates, all but three of the states reviewed have developed

concentration thresholds to which the initial testing results must be compared. Those states

without established thresholds (Louisiana17, Massachusetts, and Rhode Island), use the testing

results as a starting point for evaluating the potential risks of an industrial waste reuse project.

 16 U.S. EPA, Test Methods for Evaluating Solid Waste, Document Number SW-846, Chapter Nine. EPA

periodically updates sections of SW-846; an up-to-date version can be found at http://www.epa.gov/epaoswer/

hazwaste/test/sw846.htm.

17 Louisiana has no leachate thresholds, but does have allowable lifetime metal loadings (lbs./acre).
13

Exhibit 3-2

CHARACTERISTICS OF STATE INDUSTRIAL WASTE REUSE PROGRAMS

Scope of

Program

Testing Methods

Required*

Individual

Constituent

Thresholds?

Basis of Leachate

Thresholds (DWS, State

DWS, RCRA) **

Waste

Classification

Categories?

Streamlined

Authorization

Process***

AL General TCLP Yes 50 % of RCRA TC Levels No Prior Notice

CA General TCLP Yes RCRA TC Levels No --

IL Foundry TCLP Yes DWS Yes (only 1 reuse

category)

Prior Notice;

Waste Exemption

IN Foundry TCLP Yes Variable % of RCRA TC

Levels

Yes Prior Notice;

Waste Exemption

IA Foundry/

Fly Ash

TCLP Yes 90% of RCRA TC Levels No Waste Exemption

LA General TCLP, Totals No# -- Yes General Permit

MA General TCLP, others## No -- No --

ME General TCLP, Totals Yes Not specified No General Permit

MI General TCLP Yes 10% of RCRA TC Levels† Yes --

MN General TCLP Yes RCRA TC Levels No --

NY General TCLP Yes RCRA TC Levels No --

OH Foundry TCLP Yes Up to 30x State DWS Yes Prior Notice;

Waste Exemption

PA General TCLP, Totals Yes

Variable % of RCRA TC

Levels

No General Permit

RI General Unspecified

leachate, others††

No -- No --

TN Foundry TCLP Yes 10x DWS No Prior Notice;

Waste Exemption

TX General TCLP, other††† Yes Unknown Yes Prior Notice

WV General TCLP, Totals Yes DWS No --

WI Foundry/

Fly Ash

TCLP, Totals Yes Variable multiple of DWS Yes Prior Notice;

Waste Exemption

* TCLP: Toxicity Characteristic Leaching Procedure

Totals: Totals analysis to determine waste composition

** DWS: Federal Drinking Water Standards

RCRA TC Levels: Resource Conservation and Recovery Act Toxicity Characteristic threshold concentrations

*** Some states have developed streamlined authorization procedures for specific types of waste and reuses. These include:

Waste exemption – material is exempt from non-hazardous industrial waste regulations and can be freely reused.

Prior notification required for reuse – in some cases prior notice is combined with a requirement for some degree of review

and approval.

General permits – these permits may be issued authorizing a particular type of reuse for qualified applicants.

# Louisiana has no leachate thresholds, but does have allowable lifetime metal loadings (lbs./acre).

# # In Massachusetts, requirements for additional tests depend on the specific situation.

† This basis applies to incorporation of waste into asphalt or concrete. Michigan applies a one in one million risk factor for

uncontrolled uses.

†† Rhode Island requires representative waste characterization, including physical and chemical analyses, but does not specify

testing methods.

††† Seven-day distilled leachate test required for some class definitions.
14

Exhibit 3-3

OTHER REQUIREMENTS OF STATE INDUSTRIAL WASTE REUSE PROGRAMS

Siting Requirement Considerations

Potable Wells

Ground WaterSurface Water

Wetlands

Floodplain

Soil Type

Critical

Habitat

Residential

Other

Waste Sampling and

Testing Frequency

AL X X X a 4 times per year

CA --------------------Not Applicable--------------------- Not specified

IL --------------------Not Applicable--------------------- Every year

IN X X X b Every 2-5 years

IA --------------------Not Applicable--------------------- 4 times per year to every

year

LA X X X X X X X c Every year

ME X X X X X Not specified

MA --------------------Not Applicable--------------------- Not specified

MI --------------------Not Applicable--------------------- Every year

MN X X X X X X b,d Not specified

NY --------------------Not Applicable--------------------- Variable

OH X X X X X e Every year

PA X X X X Every year

RI --------------------Not Applicable--------------------- Every year

TN X X X X X Every 2 years

TX --------------------Not Applicable--------------------- Not specified

WV X X X X Every year

WI X X X X d Every 1-5 years

a. Less than 5 feet above an aquifer

b. Karst topography

c. Sensitive ecologic areas within 1,000 ft

d. Air emissions

e. Leach field

3.1.3 Waste Classification Categories

Seven of the state programs reviewed have created waste classification categories in an

effort to encourage beneficial reuse. These categories are defined by ranges of contaminant

thresholds for specific reuses and/or waste types. The underlying logic is that reuse projects

involving "cleaner" wastes, smaller volumes of waste, and activities that are less "risky" should

have fewer restrictions placed on them. For example, there are fewer restrictions on using an

industrial waste for manufacturing another product, which has a very low potential for causing

adverse environmental impacts, than on applying waste to agricultural soils.

States face trade-offs in deciding whether to establish a waste reuse classification system.

While a classification system requires an up-front investment of resources on the part of

regulators, it can streamline the process for reviewing and authorizing reuse projects. And while

states that do not develop a classification system retain a higher degree of control in evaluating

each beneficial reuse project on its own merits, each reuse activity or project will likely require
15

additional state resources to determine whether the proposed reuse of material from a specific

facility is appropriate.

3.1.4 Authorization Process for Reuses

States use a variety of approaches for approving reuse of non-hazardous industrial waste.

A key distinguishing factor across state programs is the extent to which they provide streamlined

authorization processes, which can greatly reduce the effort required for a foundry and an end

user to initiate and sustain a reuse project. Streamlined processes allow for other than case-bycase review of proposed reuses, thereby simplifying standardizing the review process, which can

lead to a shorter and more predictable timeline for project approval. They also can lead to

improved and more transparent decision-making by providing clear criteria for determining

appropriate reuses.

Ten of the state programs reviewed have codified specific standards that define

streamlined procedures, depending on the reuse activity, volume of waste to be reused, and

contaminant concentrations present in the waste. These procedures range from general

permitting to exempting wastes meeting strict criteria from industrial waste regulations. Specific

streamlined procedures available in individual states are summarized above in Exhibit 3-2 (see

far right column). The full spectrum of state approaches to project authorization is illustrated in

Exhibit 3-4 and examples of these approaches are cited in Exhibit 3-5.

Exhibit 3-4

OPTIONS FOR STREAMLINING THE AUTHORIZATION PROCESS

ProjectSpecific

Permit

General

Permit

Prior

Notice

Waste

Exemption*

Increased Streamlining (simpler, faster approval)

* Exemption from classification as an industrial waste.
16

Exhibit 3-5

EXAMPLES OF TECHNIQUES FOR STREAMLINING THE AUTHORIZATION PROCESS

State Authority Website Description

Waste ExemptionIllinois 35 Illinois Administrative Code Part

817 – Requirements for New Steeland Foundry Industry WastesLandfills

http://www.ipcb.state.il.us/Title_35/ main.htm

Sand meeting the leachate concentration thresholds can be reused withoutnotifying the state (unless the sand is reused in land applications).

Tennessee Beneficial Use of Nontoxic Spent

Foundry Sand - Policy

http://www.state.tn.us/environment/swm/SWPolicyManual.pdf

Sand from iron and aluminum foundries meeting leachate concentration

thresholds can be reused in certain uses without review or notification from thestate, although the foundry must maintain project records on-site.

Prior NoticeAlabama Chapter 335-13-4.26(3) (Permit

Requirements for Disposal ofFoundry Wastes)

http://www.adem.state.al.us/Regulations/regulations.htm

Prior to reuse, an applicant must "certify" the foundry waste by submitting acompleted Solid/Hazardous Waste Determination Form and a TCLP analysis formetals. No response or approval from the state is required.

Indiana Foundry Sand Waste Classification

Guidelines

http://www.in.gov/idem/land/pubsforms/guidance.html

Once the state has classified foundry sand as Type III or Type IV based on TCLP

or totals testing, no additional state approval is required prior to reuse.

General PermitLouisiana Title 33, Environmental Quality Part

VII, Solid Waste, Subpart 1, Chapter11, Section 1103 (C).

http://www.deq.state.la.us/planning/regs/ title33/index.htm

Land application only: "The administrative authority may issue a singlebeneficial-use permit for multiple beneficial-use locations provided that thepermit application includes required information for each location, each locationmeets the standards provided in this Chapter, and the same solid waste stream

(from a single generation site) is disposed of at all locations. The multiplelocations will be considered as one facility and each location will be a unit of thefacility."

Pennsylvania Regulation: Chapter 287 of the

Pennsylvania Code, Residual WasteManagement - General ProvisionsGeneral Permits relevant to foundrysand: WMGR016, WMGR019,WMGR021.

http://www.pacode.com/secure/data/025/chapter287/chap287toc.htmlhttp://www.dep.state.pa.us/dep/deputate/airwaste/wm/MRW/docs/GP_BU_PERMITS.htm

"General permit—A regional or Statewide permit issued by the Department for a

specified category of beneficial use or processing of solid waste, the terms andconditions of which allow an original applicant, a registrant and person ormunicipality that obtains a determination of applicability, to operate under thepermit if the terms and conditions of the permit and certain requirements of thisarticle are met."
17

Waste Exemption

The most streamlined procedure is to grant an exemption from non-hazardous industrial

waste management requirements when the material meets specified, stringent thresholds.

Indiana and Iowa both exempt waste from notification requirements if it is certified to meet state

reuse standards and is being used in a listed, state-approved activity.

Several states provide an exemption under more limited conditions. For example, in

Ohio industrial waste material can be reused to manufacture another product without prior

notification if it meets leachate thresholds equivalent to 30 times the state drinking water

standards (DWS). To be reused in construction of roads and parking lots, though, the waste must

meet leachate thresholds equivalent to five times the state DWS. In Wisconsin, wastes meeting

specific thresholds are exempt from notification for a single reuse category – manufacturing

another product.

Prior Notice

Many states have streamlined authorization procedures for industrial waste reuse that

allow projects to proceed with only prior notification. In Ohio, prior notification is required for

all transportation embankment projects, with certain large projects also requiring a degree of

departmental review and approval.18 Illinois and Alabama both require notification of any reuses

on their approved lists, with Alabama also requiring departmental approval.

General Permits

States also issue general permits that allow multiple qualified applicants to engage in

particular reuses. States implement this approach in several different ways. For example,

Pennsylvania issues general permits that cover a particular reuse; any producer of waste material

meeting the specified thresholds can apply to join the permit. Maine issues general permits that

allow end users to receive by-products from generators without additional approval from the

State. In Louisiana, most approvals are on a case-by-case basis, but permits can be issued for a

specific reuse of waste material from multiple sources at multiple locations.

3.1.5 Other Common Requirements

In addition to the initial characterization of the waste, states frequently include siting

and/or sampling and testing requirements in their programs to ensure that industrial waste reuse

will be safe (see Exhibit 3-3).

 18 For projects in Ohio involving reuse of foundry sand and bottom ash, there is no need for prior notice if

leach tests of the material consistently meet Ohio drinking water standards. However, facilities are required to

submit project summaries to Ohio EPA.
18

Siting Requirements

Ten states place restrictions on the location of industrial waste reuse projects,

such as minimum distance from ground-water, surface-water, and drinking-water

sources; floodplains and wetlands; protected ecological and environmentally sensitive

areas; and property fencelines.

Sampling and Testing Requirements

All state programs reviewed have requirements for the frequency of waste

sampling and testing. These requirements can include follow-up sampling and testing to

confirm that the waste’s composition has not changed. This sampling may be conducted

annually or if the process generating the waste changes. Typically, state programs also

have requirements for notifying the relevant state agency of the reuse activity (e.g., prior

to initiating reuse project, annual reports of project status and conditions, and updates

following any changes to the reuse process). There also may be requirements for

notifying the public.
19

STATE REGULATIONS AND POLICIES

ADDRESSING FOUNDRY SAND REUSE CHAPTER 4

4.0 TAILORED REGULATION OF SAND REUSE

With costs for landfilling used sand typically ranging from $10 to $50 per ton in tipping

fees plus transportation costs, foundries have a significant financial incentive to pursue

alternatives to landfill disposal. States are also motivated to stretch their limited resources by

streamlining the authorization process for reuses. For example, developing clear requirements

for collecting, preparing, and submitting data can improve the quality of documentation that

supports proposed reuses and reduce the need for follow-up submissions. In addition, some

programs allow sand that meets stringent concentration thresholds to be reused without preapproval from the state. In some cases programs even provide exemptions from the industrial

waste regulations for qualifying sand (see discussion of streamlined authorization in Chapter 3).

Of the 18 state programs EPA reviewed, seven have guidance or regulations specific to

beneficial foundry sand reuse, including Illinois, Indiana, Iowa, Ohio, Tennessee, West Virginia,

and Wisconsin.

While states' approaches to regulating foundry sand reuse are similar to those used for

regulating industrial waste reuse in general, sand reuse programs specifically consider the

characteristics of foundries and used sand, and the likely reuses. The many binders, curing

processes, raw materials, and metals used in the casting process all affect the composition of

foundry sand. The variation in sand composition across foundries poses a challenge in devising

guidelines and/or regulations that provide for environmentally safe sand reuse. States have

strived to tailor foundry sand reuse requirements by emphasizing areas of concern (such as

particular metals and binder types used by foundries) and addressing likely reuse scenarios.

4.1 STATE APPROACHES TO REGULATING SAND REUSE

The set of regulatory tools selected by a given state reflects the trade-offs inherent in

balancing the desire to encourage sand reuse with the need to protect human health and the

environment. It is important to look beyond differences in a single program feature, such as

leachate thresholds, and examine the full set of program requirements for sand reuse across

states. Three major approaches to reviewing programs and policies are available to states

wishing to amend an existing program or establish a new one.
20

4.1.1 Addressing Different Types of Foundries and Foundry Sand

Certain foundry operations and sand types are more likely to cause environmental

concern than others. States vary in how they choose to address these. For example, Iowa's

regulations address reuse of all types of sand; Tennessee's address reuse of sand from ferrous and

aluminum foundries; and Wisconsin's address reuse of sand from ferrous foundries.

4.1.2 Combining Concentration Thresholds and Other Regulatory Requirements

States combine concentration thresholds and other regulatory requirements in a variety of

ways to ensure that sand reuse is environmentally safe. For example, while leachate

concentration thresholds in Illinois are among the most stringent, wastes meeting these

thresholds are then exempt from industrial waste management requirements and can be reused in

any way without regulatory oversight. Tennessee's leachate concentration thresholds are less

stringent than Illinois', but applicants must submit reuse reports every two years and, in some

cases, undergo a project review by the state. Wisconsin has less stringent leachate concentration

thresholds than Tennessee, but requires both additional testing and annual reuse certification.

4.1.3 Balancing Allowable Reuses and Regulatory Requirements

In developing programs, states strike a balance between the potential risks associated

with a reuse and the stringency of regulatory requirements. For example, reuse of sand in a

"less-risky" activity, such as manufacturing another product, is commensurate with a reduced

regulatory burden for the applicant. Similarly, meeting more stringent regulatory requirements,

such as lower concentration thresholds and more frequent sampling and testing of sand, will

create a wider range of reuse possibilities, in terms of both the types of reuse and the volume of

sand that may be used in a project.

4.2 COMPARISON OF STATE REQUIREMENTS FOR SPECIFIC REUSES

Comparing requirements for specific reuses of foundry sand provides additional insight

into the approaches adopted by states. The following section presents requirements for the four

broad categories of reuses across the seven states with programs that specifically address foundry

sand reuse:19 (1) manufacturing another product, (2) structural fill, (3) pipe bedding and backfill,

and (4) soil manufacturing, soil amendments, land applications, and composting.

 19 Regulatory requirements across states for a fifth reuse category – landfill uses – are not included in this

comparison because states generally require only that the sand be non-hazardous, and some states do not consider

landfill applications as "beneficial reuse."
21

4.2.1 Reuse in Manufacturing Another Product

Description

In general, states define the beneficial reuse of foundry sands as a raw material in the

manufacture of another product to include the following products:

• asphalt;

• bricks;

• cement;

• concrete block;

• flowable fill;

• grout; and

• lightweight aggregate.

Regulatory Requirements

Of all reuses, manufacture of another product is the most inert and poses the least

environmental risk; consequently, it is one of the least stringently regulated reuses. As shown in

Exhibit 4-1, in several states the foundry sand need only qualify as non-hazardous (e.g., meet

RCRA toxicity characteristic (TC) levels using TCLP - Wisconsin) or marginally non-hazardous

(90 percent of RCRA TC levels - Iowa). However, in most states the maximum allowable

leachate concentration for constituents of concern ranges from values equivalent to federal

drinking water standards to 30 times these values.

The process of obtaining approval for this type of reuse varies across states. For

example, Iowa, Ohio, and Tennessee do not require the foundry to provide notification or seek

agency review/approval prior to the start of the reuse project, so long as the sand meets the

established concentration thresholds. However, in West Virginia, foundries must submit a

Beneficial Use Plan and gain agency approval prior to reuse.
22

Exhibit 4-1

REUSING FOUNDRY SAND AS A RAW MATERIAL IN MANUFACTURING ANOTHER PRODUCT –

COMPARISON OF MAXIMUM ALLOWABLE LEACHATE CONCENTRATIONS (in mg/L) AND OTHER

REQUIREMENTS

CONSTITUENT THRESHOLDS

RCRA METALS IL* IN* IA* OH TN WV WI*

Arsenic 0.05 0.50 4.5 1.5 - 0.05 5.0

Barium 2.0 10.0 90.0 60.00 20.00 1.0 100

Cadmium 0.005 0.10 0.90 0.15 0.05 0.01 1.0

Chromium, Total 0.1 0.50 4.5 3.0 1.00 0.05 5.0

Lead 0.0075 0.50 4.5 1.5 0.50 0.05 5.0

Mercury - 0.02 0.18 0.06 0.02 0.002 0.2

Selenium 0.05 0.10 0.90 1.00 0.50 0.01 1.0

Silver - 0.50 4.5 - - 0.05 5.0

OTHER CONSTITUENTS

Benzene 0.005 - 0.45 - - - 0.5

Chloride 250.0 250 - - - - -

Copper 5.0 2.5 - - 13.00 1,500 (totals limit) -

Cyanide (Total) - 0.20 - 0.60 2.00 0.60 -

Fluoride 4.0 - - 12.0 - 12 -

Formaldehyde - - - - 300.0 (totals

limit)

- -

Iron 5.0 1.5 - - - - 3.0

Manganese 0.15 0.05 - - - - -

Molybdenum - - - - - 18 (totals limit) -

Nickel - 0.20 - - 1.0 200 (totals limit) -

Nitrate 10.0 - - - - - -

Phenols (Total) - 0.30 - 10.5 15.00 10.5 -

pH - 6.0-9.0 5.0-10.0 - - - -

Sodium - 2,500 - - - - -

Sulfates 400.0 2,500 - - - - -

Sulfide (Total) - 5.0 - - - - -

Zinc 5.0 2.5 - - - 2,800 (totals limit) -

Basis for Thresholds U.S. DWS 10% of

RCRA TC

levels

90% of

RCRA TC

levels

30x Ohio DWS 10x U.S. DWS 1% of RCRA TC

levels

RCRA TC

levels

OTHER REQUIREMENTS

Monitoring

Frequency for Sand

Annually Every 2 - 5

years

Quarterly –

Annually

Annually Every 2 years Annually Every 1 - 5

years

Submission of

Regular Reports

For each

project

No On-site

records

On-site records On-site records No Yes

Siting Requirements N/A Floodplain,

Wetlands,

Critical

Habitat

N/A SW, Potable

Wells,

Wetlands,

Leachfields

GW, SW,

Floodplain,

Certain Soil

Types, Potable

Wells

GW, SW, Floodplain,

Certain Soil Types

GW, SW,

Wetlands,

Critical

Habitat

Notes:

* IN, IL, IA, and WI have concentration limits for additional constituents.

IN – The maximum allowable concentrations apply to Type IV waste classification.

WI – TCLP limits are Category V thresholds.

WV – based some of its thresholds on Ohio’s Policy 400.007.

RCRA TC: RCRA Toxicity Characteristic thresholds. RCRA TC thresholds are approximately equivalent to 50 - 200 times federal drinking water

standards (DWS); DWS are approximately equivalent to 0.5 – 2.0 percent of RCRA TC thresholds.

GW: Ground water

SW: Surface water
23

4.2.2 Reuse as Structural Fill

Description

Structural fill is one of the most common beneficial reuses of sand specified in the state

programs reviewed. States tend to define structural fill in engineering terms, such as building or

equipment supportive base or foundation, foundation backfill, road base, and sub-base. Illinois

and Iowa do not use the general term "structural fill," but rather identify several specific uses

considered to be "structural fill."

Regulatory Requirements

As shown in Exhibit 4-2, the constituent concentration requirements for reuse as

structural fill are generally equivalent to those for reuse in manufacturing another product.

However, Wisconsin requires that foundry sand meet Category 4 standards for reuse as structural

fill, while the less stringent thresholds for Category 5 apply for reuse in manufacturing another

product. In Ohio, foundry sand must meet more stringent leachate thresholds (ranging from the

Ohio drinking water standards to 20 times these standards) to qualify for use as structural fill,

compared to 30 times the Ohio drinking water standards for use as a raw material in

manufacturing another product.

Reuse of sand as structural fill also tends to require a more intensive application/approval

process. For example, Iowa requires foundries to obtain approval for use of sand in structural fill

projects but not for manufacturing another product. Similarly, Tennessee requires review and

notification prior to use in structural fill but not for use in manufacturing another product.
24

Exhibit 4-2

REUSING FOUNDRY SAND AS STRUCTURAL FILL - COMPARISON OF MAXIMUM ALLOWABLE LEACHATE

CONCENTRATIONS (in mg/L) AND OTHER REQUIREMENTS

CONSTITUENT THRESHOLDS

RCRA METALS IL* IN* IA* OH TN WV WI*

Arsenic 0.05 0.50 4.5 1.0 - 0.05 -

Barium 2.0 10.0 90.0 40.00 20.00 1.0 10.0

Cadmium 0.005 0.10 0.90 0.1 0.05 0.01 0.025

Chromium, Total 0.1 0.50 4.5 2.0 1.00 0.05 -

Lead 0.0075 0.50 4.5 1.0 0.50 0.05 0.075

Mercury - 0.02 0.18 0.04 0.02 0.002 0.01

Selenium 0.05 0.10 0.90 1.00 0.50 0.01 -

Silver - 0.50 4.5 - - 0.05 -

OTHER CONSTITUENTS

Benzene 0.005 - 0.45 - - - -

Chloride 250.0 250 - - - - -

Copper 5.0 2.5 - - 13.00 1,500 (totals limit) -

Cyanide (Total) - 0.20 - 0.40 2.00 0.60 -

Fluoride 4.0 - - 8.0 - 12 -

Formaldehyde - - - - 300.0 - -

Iron 5.0 1.5 - - - - 3.0

Manganese 0.15 0.05 - - - - -

Molybdenum - - - - - 18 (totals limit) -

Nickel - 0.20 - - 1.0 200 (totals limit) -

Nitrate 10.0 - - - - - -

Phenols (Total) - 0.30 - 7.0 15.00 10.5 -

pH - 6.0-9.0 5.0-10.0 - - - -

Sodium - 2,500 - - - - -

Sulfates 400.0 2,500 - - - - -

Sulfide (Total) - 5.0 - - - - -

Zinc 5.0 2.5 - - - 2,800 (totals limit) -

Basis for Thresholds U.S. DWS 10% of

RCRA TC

levels

90% of

RCRA TC

levels

Ohio DWS

to 20x

Ohio DWS

10x U.S.

DWS

1% of RCRA TC

levels

RCRA TC

levels

OTHER REQUIREMENTS

Monitoring

Frequency for Sand

Annually Every 2 - 5

years

Quarterly –

Annually

Annually Every 2 years Annually Every 1 - 5 years

Submission of

Regular Reports

For each

project

No On-site

records

On-site

records

On-site records No Yes

Siting Requirements N/A Floodplain,

Wetlands,

Critical

Habitat

N/A SW, Potable

Wells,

Wetlands,

Leachfields

GW, SW,

Floodplain,

Certain Soil

Types, Potable

Wells

GW, SW, Floodplain,

Certain Soil Types

GW, SW,

Wetlands, Critical

Habitat

Notes:

* IN, IL, IA, and WI have concentration limits for additional constituents.

IN – The concentration limits apply to Type IV waste classification.

OH – Maximum allowable concentrations and other requirements (e.g., reporting) vary according to the volume of foundry sand

that is used in the project.

WI – TCLP limits are Category 4 thresholds.
25

4.2.3 Reuse as Backfill and Pipe Bedding

Description

Backfill and pipe bedding are unencapsulated fill, but specific definitions vary across the

seven states. Ohio allows foundry sand to be used as pipe bedding or as fill for "empty borrow

pits created during road construction or other construction activities." Tennessee allows foundry

sand to be used as fill in "abandoned or closed mines or strip mine areas." Wisconsin’s guidance

broadly defines unencapsulated fill as "unconfined geotechnical fill material." It includes fill "as

part of the construction of a building, parking area, utility trench, or other structural

improvement, where the industrial by-product is not structurally confined."

Regulatory Requirements

Compared to the previous two uses, Ohio and Wisconsin have more stringent

concentration thresholds for backfill. The other five states have the same thresholds for most

uses, including backfill. In Ohio, foundry sand must meet 20 times the Ohio drinking water

standards, at a minimum, and may be required to meet a lower threshold (the Ohio drinking

water standards or five times the standards), depending on the specific project characteristics. In

Wisconsin, the used sand must meet at least Category 3 standards, which are substantially more

stringent than the Category 5 standards established for using sand in manufacturing another

product.20 In addition, to classify as Category 3, foundry sand must meet thresholds for three

additional constituents (aluminum, antimony, and beryllium). In Illinois and Indiana, all foundry

sand meeting the established concentration thresholds is exempt from state regulations and can

be reused in any manner. Tennessee requires review and notification prior to use. Exhibit 4-3

summarizes the regulatory requirements applicable for use as backfill.

 20 Wisconsin uses five categories of waste, with Category 1 having the most stringent requirements and

Category 5 having the least stringent.
26

Exhibit 4-3

REUSING FOUNDRY SAND AS BACKFILL – COMPARISON ACROSS STATES OF MAXIMUM ALLOWABLE

LEACHATE CONCENTRATIONS (in mg/L) AND OTHER REQUIREMENTS

CONSTITUENT THRESHOLDS

RCRA METALS IL* IN* IA* OH TN WV WI*

Arsenic 0.05 0.5 4.5 1.0 - 0.05 0.05

Barium 2.0 10.0 90.0 40.0 20.00 1.0 4.0

Cadmium 0.005 0.10 0.90 0.10 0.05 0.01 0.005

Chromium, Total 0.1 0.50 4.5 2.0 1.00 0.05 0.10

Lead 0.0075 0.50 4.5 - 0.50 0.05 0.015

Mercury - 0.02 0.18 0.04 0.02 0.002 0.002

Selenium 0.05 0.10 0.90 1.0 0.50 0.01 0.10

Silver - 0.50 4.5 - - 0.05 -

OTHER CONSTITUENTS

Benzene 0.005 - 0.45 0.10 - - -

Chloride 250.0 250 - - - - -

Copper 5.0 2.5 - - 13.00 1,500 (totals limit) -

Cyanide (Total) - 0.20 - 0.40 2.00 0.60 -

Fluoride 4.0 - - 8.0 - 12 8.0

Formaldehyde - - - - 300.0 - -

Iron 5.0 1.5 - - - - 1.50

Manganese 0.15 0.05 - - - - 0.25

Molybdenum - - - - - 18 (totals limit) -

Nickel - 0.20 - 1.0 200 (totals limit) -

Nitrate 10.0 - - 200.0 - - -

Phenols (Total) - 0.30 - 7.0 15.00 10.5 12.0

pH - 6.0-9.0 5.0-10.0 - - - -

Sodium - 2,500 - - - - -

Sulfates 400.0 2,500 - - - - -

Sulfide (Total) - 5.0 - - - - -

Zinc 5.0 2.5 - - - 2,800 (totals limit) -

Basis for

Thresholds

U.S. DWS 10% of

RCRA TC

levels

90% of

RCRA TC

levels

Ohio DWS to

20x Ohio

DWS

10x U.S.

DWS

1% of RCRA TC levels U.S. DWS to

2x U.S. DWS

OTHER REQUIREMENTS

Monitoring

Frequency for

Sand

Annually Every 2 - 5

years

Quarterly –

Annually

Annually Every 2

years

Annually Every 1 - 5

years

Submission of

Regular Reports

For each

project

No On-site

records

On-site

records

On-site

records

No Yes

Siting

Requirements

N/A Floodplain,

Wetlands,

Critical

Habitat

N/A SW, Potable

Wells,

Wetlands,

Leachfields

GW, SW,

Floodplain,

Certain Soil

Types,

Potable

Wells

GW, SW, Floodplain,

Certain Soil Types

GW, SW,

Wetlands,

Critical Habitat

Notes:

* IN, IL, IA, and WI have concentration limits for other constituents.

OH- Category 2 waste is the least stringent category in which foundry sand used for this application may fall.

WI- Concentration thresholds based on Category 3 requirements.
27

4.2.4 Reuse in Soil Blending, Land Applications, and Composting

Description

This category includes the following four related uses: soil blending ingredient, soil

amendment, direct surface or subsurface application to land, and composting. These uses serve

to improve the characteristics and performance of agricultural or horticultural soil. They involve

mixing sand with soil prior to being applied, or direct application to land.

Regulatory Requirements

As shown in Exhibit 4-4, these reuses typically have the most stringent state

requirements. Although four of the seven states do not explicitly allow land application and soil

blending, facilities can seek state approval for these and other beneficial reuses by applying for a

waiver or by proposing a reuse project for review. Following are the beneficial reuses

specifically addressed by three states:

• Soil blending. Only Ohio specifies the beneficial reuse of foundry sand as an

ingredient in commercial soil blending. Under the Ohio policy, the sand may

constitute no more than 50 percent of the mixture, and the blended soil may be

used only for growth of trees or ornamentals (excluding sod farms).21 The

mixture may not be used for growth of crops intended for human

consumption. Thus, it may not be applied to grazed pastures, to home

fruit/vegetable gardens, or to agricultural crops or fruit trees.

• Soil amendment. Indiana is the only state that identifies this beneficial reuse

of foundry sand. The state defines "soil amendment" as "foundry sand that

has been mixed with one or more other materials to form a product, which

could then be sold, re-mixed, applied to land, or otherwise used as soil or as

soil substitute..." Unlike Ohio, Indiana does not limit the volume of sand that

may be incorporated into agricultural or horticultural soils.

• Land application. Only Indiana specifically allows direct surface and/or

subsurface application of foundry sand to land. The sand must be evenly

applied on lands intended for agricultural and/or horticultural use.

• Composting. Ohio and Tennessee allow this reuse, but not use as a postcomposting additive or in land application.

 21 Permits for unrestricted use in soil blending can be obtained in Ohio on a case-by-case basis.
28

Exhibit 4-4

REUSING FOUNDRY SAND FOR SOIL BLENDING, LAND APPLICATIONS, AND IN COMPOSTING -

COMPARISON ACROSS STATES OF MAXIMUM ALLOWABLE CONCENTRATIONS AND OTHER

REQUIREMENTS

Leachate Standards Total Metals (mg/kg)

CONSTITUENT (mg/L) Soil Standards

OH TN1 IN2 IN3

RCRA METALS

Arsenic 0.25 - 41 75

Barium 10.00 20.00 - -

Cadmium 0.025 0.05 39 85

Chromium, Total 0.50 1.00 2,000 3,000

Lead 0.25 0.50 300 840

Mercury 0.01 0.02 17 57

Selenium 0.25 0.50 100 100

Silver - - - -

OTHER CONSTITUENTS

Benzene - - - -

Copper - 13.004 750 4,300

Cyanide (Total) 0.20 2.005 - -

Fluoride 4.0 - - -

Formaldehyde - 300.0 -

Molybdenum - - 75 75

Nickel - 1.00 210 420

Nitrate - - - -

Phenols (Total) 3.5 15.00 - -

pH - - > 6.56 -

Zinc - - - -

Basis for

Thresholds

5x U.S. DWS

(except for cyanide)

10x U.S. DWS Based on Federal guidelines that govern the land

application of sewage sludge 40 CFR 503

OTHER REQUIREMENTS IN OH TN

Monitoring Frequency for

Sand

Every 2 – 5 years Annually Every 2 years

Submission of Regular

Reports

No On-site records On-site records

Siting Requirements Floodplain, Wetlands,

Critical Habitat

SW, Potable Wells, Wetlands,

Leachfields

GW, SW, Floodplain, Certain

Soil Types, Potable Wells

Notes:

1

 Land application is not a specified use.

2

 Maximum allowable concentrations to use as a soil amendment. Concentrations are in mg/kg on a dry weight basis. 3

 Maximum allowable concentrations to use in land applications. Concentrations are in mg/kg on a dry weight basis. 4

 The concentration limit is a maximum contaminant level goal (MCLG) in the federal DWS. 5

 Concentration value is based upon modified TCLP extraction test; refer to ASTM method D3987-85. 6

 The pH requirement applies to soils with a cadmium concentration over 2 mg/kg dry weight.

IN- Use as a soil amendment or in a land application also requires that the sand meet Type III criteria (TCLP results of 10% of

RCRA values).

OH- Soil blending and composting are allowed; plan approval is required for land application on a case-by-case basis.
29

CASE STUDIES OF BENEFICIAL USES OF FOUNDRY SAND CHAPTER 5

5.0 PURPOSE OF CASE STUDIES

Four beneficial reuse projects were selected as case studies to demonstrate the breadth of

reuse activities for foundry sand and the implementation of industrial by-product reuse

regulations in different states. Exhibit 5-1 lists the location, type of reuse, and major participants

for the case studies. In each of the four states, non-hazardous foundry sand must meet certain

contaminant criteria to be certified for reuse. Each state specifies how the sand can be used. In

most cases, the alternatives to reuse are to store or dispose of the foundry sand in a companyowned monofill or to send it to a landfill, where it is frequently used as daily cover.

Exhibit 5-1

BENEFICIAL FOUNDRY SAND REUSE CASE STUDIES

State Type of Reuse Participants

Ohio Soil Amendment Kurtz Brothers, Inc., Ford Foundry, and

Dugan's Garden Center

Wisconsin Structural Fill for Embankments Waupaca Foundry and Wisconsin

Department of Transportation

Michigan Asphalt Resource Recovery Corporation and Asphalt

Paving, Inc.

West Virginia Parking Lot Construction HK Casting and Weston Ford

These case studies are success stories. They show how foundry sand can be reused under

set guidelines with no adverse environmental impacts. Economic and operational considerations

are also important elements of these reuse efforts that affect both the initial feasibility of a

project and, ultimately, its sustainability. This chapter presents an overview of the case studies

and summarizes their findings, focusing on the factors that were seen to facilitate beneficial

reuse of sand and those that are barriers.
30

5.1 OVERVIEW OF FOUNDRY SAND REUSE CASE STUDIES

Following are brief descriptions of the four case studies. Appendix B provides more

detailed descriptions that explore the state regulatory framework governing sand reuse, the

performance of the sand (including environmental performance), and the economic and

operational effects of reuse from the perspectives of the foundry and the end user.

5.1.1 Soil Amendment – Ohio

Kurtz Brothers, in Ohio, has been a leader in the reuse of foundry sand for the past 20

years. The company produces a variety of soil blend products that are sold directly and through

garden centers throughout Ohio. The Ford Foundry in Brookpark, Ohio, has been the largest

sand supplier to Kurtz for the past 15 years, providing over 240,000 tons of sand to Kurtz in

2001.

As part of an agreement with the state, Ford conducts sand leachate tests annually, and

Kurtz conducts quarterly leachate and total metals tests on its soil products made with foundry

sand. Kurtz also submits an annual report to the Ohio EPA, describing the test results and any

problems that arose with the reuse. The major barrier to Kurtz’s increasing reuse of sand is the

high transportation costs associated with expanding the network of foundries supplying sand.

5.1.2 Structural Fill – Wisconsin

The Waupaca Foundry provides sand for structural fill in Wisconsin Department of

Transportation (DOT) highway embankment projects. Ten months worth of excess sand (80,000

tons) was used in the latest project. Waupaca’s sand was certified as meeting required Category

2 or 3 standards. The sand is mixed with bentonite clay so it is relatively impermeable. The

embankment requires only a clay cap; no liner is needed. The leachate volumes from the

embankment will be measured twice each year.

From Waupaca’s perspective, two key factors contributed to the project’s success: (1)

Waupaca’s process improvements minimized any additional screening required prior to reuse;

and (2) the ability to have off-site storage near the project minimized transportation costs.

5.1.3 Asphalt – Michigan

The Resource Recovery Corporation (RRC), a foundry-owned collaborative effort,

undertakes reuse projects with the sand and other foundry residuals collected from member

foundries. By consolidating sand, RRC can provide a consistent, reliable supply to its end users.

RRC produces fine aggregate for use in making asphalt. In 2001, RRC sent over 31,000 tons of

processed foundry aggregate to Asphalt Paving, Inc. (API). API began to use foundry processed

aggregate in its product in 1997 and had used over 125,000 tons of this material as of December

2001.
31

RRC’s processing facility is located at an Allied Waste System landfill. As a result, RRC

is able to complement its processing capability with long-term storage for future use and or

disposal of residuals.

5.1.4 Parking Lot Construction – West Virginia

Since West Virginia approved foundry sand reuse in 2000, HK Casting has completed

two projects reusing 21,000 tons of sand as sub-base for parking lots. The foundry produces

5,000 – 6,000 tons of sand a year, and the parking lot projects have reused all of its stored excess

sand.

HK was a key player in working with West Virginia to develop the state’s reuse policy.

The additional testing requirement for reusing HK’s sand for beneficial reuse is to conduct a

totals analysis for four metals. The TCLP test was already required for disposal of reused

foundry sand in a municipal landfill, although HK’s sand must meet stricter leachate standards to

be reused.

For each project, HK submits a reuse plan to the state that includes the use, location, and

amount of sand proposed for reuse. The state inspects the proposed reuse site to ensure that it

meets all requirements. It also has the authority to inspect and monitor the site any time before,

during, or after the beneficial reuse project.

5.2 SUMMARY OF FINDINGS

The fundamental finding from the four case studies is that all of these projects have

safely and successfully reused foundry sand following different state regulations or guidance. In

addition to there being no violations of state regulations, none of the state representatives

reported any significant public concern over foundry sand reuse or any legal challenges.

5.2.1 Differences in State Reuse Programs

All four states require that leachate tests be performed on a regular basis. These tests

address the potential for metals and additional contaminants (e.g., phenol and cyanide) to leach

from the sand. Beyond the minimum requirements, there is some variability among the states,

both in the parameters tested and in the thresholds specified. Chapters 2 and 3 as well as

Appendix A provide a more in-depth discussion of these differences.

Three states (West Virginia, Ohio, and Michigan) base their thresholds on the federal

hazardous waste guidelines (40 CFR 261.24), which establish thresholds for classification of

waste as hazardous based on leachate characteristics determined through the TCLP.22 State

limits for various beneficial reuses are set at varying ratios relative to the federal regulatory

levels. West Virginia has the most stringent requirements: for all beneficial reuse projects, the

 22 EPA Test Method 1311, specified in EPA SW-846.
32

TCLP results for foundry sand must be at least 100 times less than the federal hazardous waste

thresholds. In Michigan, the limit for foundry sand to be considered for contained uses, such as

asphalt or concrete, is set at 10 percent of the federal guidelines, or 10 times the threshold for an

inert material suitable for general reuse (whichever is higher). Wisconsin tests for a set of

parameters similar to those in the TCLP, but has adopted threshold values for each contaminant

separately, rather than applying a set ratio to values set under the federal hazardous waste

guidelines.

Most of the states have a category system that relates the characteristics of foundry sand

to allowable beneficial reuses. Michigan, Ohio, and Wisconsin have systems based on

contaminant levels in the sand, where reuse opportunities increase as the material meets stricter

contaminant standards. West Virginia has a single-tier system: sand must meet the same strict

threshold for all reuses. The differences among these states relate primarily to what threshold

levels are chosen for different types of reuse. For example the acceptable thresholds for capped

transportation embankments, an approved use in all four states, vary considerably – in many

cases by more than a factor of 10.

5.2.2 Factors Affecting the Beneficial Reuse of Foundry Sand

The key motivating factor for reusing foundry sand, both for the foundry and the end

user, is cost savings. Without reuse, foundries must pay for disposal of their sand, and the end

user must purchase virgin material. In determining whether to reuse foundry sand, foundries

weigh these disposal costs against the costs of segregating sand suitable for reuse from other byproducts and transporting it to the location of a reuse activity. For the end user, the cost of virgin

material is weighed against the cost of obtaining and using the foundry sand, including any

testing that must be performed on products containing foundry sand, any potential delays

associated with the reuse approval process, and any potential effect on sales of products

containing an industrial by-product.

One foundry mentioned that it prefers to reuse sand rather than send it to a landfill to

minimize the potential liability associated with becoming a future responsible party at a landfill

site. The Wisconsin Department of Transportation included "civic duty" as part of the rationale

for reusing foundry sand in its construction projects, noting that encouraging reuse rather than

landfilling was everybody’s responsibility. While important, these advantages are clearly

secondary to economic considerations. They were cited as significant only when the costs of

reusing foundry sand were comparable to the costs of using virgin material.

Looking across all four case studies, five factors appear to be critical to the long-term

success of beneficial reuse activities. These case studies also suggest three factors that represent

barriers to beneficial reuse of foundry sand. These factors are listed in Exhibit 5-2 and discussed

below.
33

Exhibit 5-2

FACTORS AFFECTING THE BENEFICIAL REUSE OF FOUNDRY SAND

Factors Contributing to Successful Reuse

Projects

Barriers to Reuse

C Streamlined regulatory process C Difficulty of finding new reuse opportunities

C Proximity of foundry to reuse location C Aesthetics of sand

C Temporary storage facilities

C Reliable sand supply

C Large volumes of sand required for certain

reuse projects

C Consistent sand quality

Factors Contributing to Successful Reuse Projects

Streamlined Regulatory Process

Several interviewees emphasized the importance of a streamlined approval process

designed to facilitate the reuse of industrial by-products. For example, before the promulgation

of current regulations in Wisconsin, an activity involving the beneficial reuse of sand could not

be initiated without the submittal of a formal request with extensive documentation to the

Department of Natural Resources (DNR). This type of notice was required for each individual

foundry sand reuse project. Under the current regulations, once a foundry has its sand certified

as meeting particular contaminant criteria, the sand can be used in multiple projects involving

activities for which the sand is qualified without approval by the DNR unless very large volumes

of material are used. The foundry is required to re-certify the quality of its sand twice a year and

notify the DNR how it is being reused.

Proximity of Foundry to Reuse Location

Transportation is generally the largest expense associated with reuse, comparable to

landfill costs in many areas even over short distances. Based on these case studies, the

maximum feasible distance from a foundry to a project is 25 to 50 miles. Resource Recovery

Corporation (RRC) in Michigan, a cooperative formed by local foundries to promote reuse of

their sand, is the only exception to this finding. Member foundries transport their sand up to 90

miles to RRC, which processes the sand and ships it additional distances to end users.

Temporary Storage and Reliable Supply

Temporary storage sites and a reliable sand supply go hand in hand. Together they

ensure that when sand is needed for a project, it is available. Temporary storage sites can be a

dedicated area at the reuse site or a monofill at the foundry from which sand can be removed as
34

necessary to meet high demand. A reliable sand supply guarantees that the material required for

completing a project will be available when it is needed.

Consistent Sand Quality

Several end users mentioned the need for strict quality control at the foundry to provide

homogenous material without random metal scraps or large chunks of casting cores. This need

for consistent quality also affects the viability of reuse from the perspective of the foundry.

For example, Waupaca Foundry initially had to filter its sand so that it could be reused in

construction projects. This represented an additional step that significantly increased the cost of

reuse. With process improvements over the last 10 years, however, Waupaca no longer needs to

put its sand through additional filters in order to have a homogeneous by-product, which has

made reuse much more financially attractive.

Barriers to Reuse

Finding New Reuse Opportunities

From the foundries’ point of view, one of the primary difficulties is that the reuse

opportunities are generally limited to activities on each state’s "pre-approved" list. For example,

when Waupaca Foundry submitted its application for reusing sand in pre-approved construction

activities, it also submitted an application to use blended foundry sand and baghouse dust as liner

material in manure pit construction (a reuse not on Wisconsin’s pre-approved list). Wisconsin

DNR denied the manure pit reuse application because of uncertainty about the environmental

impact of this activity. DNR would not approve this reuse unless Waupaca could provide

permeability and leachate test results on the proposed pit design. Such research and testing is

often not economically feasible for an individual foundry, making it difficult for a foundry acting

alone to develop new reuses.

The ability of foundries to develop new uses is also limited by transportation costs. For a

reuse project to be economically feasible, it must be located relatively close to the foundry or the

transportation costs become prohibitive. As noted above, these case studies suggest that

distances of up to 50 miles are feasible for projects involving a single foundry.

Aesthetics of Foundry Sand

Officials in several states mentioned that the dark brown or black color of foundry sand

prevents its use in situations where it is not covered. Wisconsin’s DNR noted that a Category 2

foundry sand, (such as that produced by Waupaca could theoretically be used as an anti-skid

agent on roads in winter, but the sand’s dark color might be aesthetically disturbing to the

general public. A related issue is the stigma that can be associated with end products containing

reused industrial by-products.
35

Large Volumes of Sand Required for Certain Reuse Projects

Many reuse projects require volumes of sand that exceed the amounts a small foundry

can supply on a reliable basis. The Wisconsin DOT noted this as a concern in some of its

projects. While the need for of large quantities of sand makes it difficult for small foundries to

compete for projects, this creates opportunities for organizations that consolidate sand from

multiple foundries for reuse, such as Kurtz Brothers and RRC.

5.2.3 Further Opportunities for Foundry Sand Reuse

To identify new reuse opportunities, foundries need to actively expand markets for

current uses or pursue markets for new uses. Larger foundries and "middlemen," such as Kurtz

Brothers and RRC, who consolidate and prepare sand for reuse, have the resources and

knowledge to increase the reuse market. RRC is actively exploring additional uses for sand and

other foundry residuals through research and development. It is especially interested in working

with the Michigan Department of Environmental Quality to expand the list of pre-approved uses.

Foundries involved in these case studies have considered additional reuse possibilities on

their own. For example, Waupaca indicated that it is hoping to expand into more "value-added"

reuse products (e.g., concrete, flowable fill, and asphalt), while maintaining its market in reusing

foundry sand in road embankment construction. However, this foundry’s experience submitting

an application for a new reuse activity not on the state’s "pre-approved" list illustrates the

challenges of attempting to expand the reuse market. It seems more likely that efforts involving

multiple foundries, or organizations that consolidate sand from multiple foundries, will have the

necessary resources to successfully expand sand reuse into new areas.