Indiana

Overview of foundry sand reuse rules

Indiana allows various reuse options for foundry sand, depending on its restricted waste classification.  Indiana law also requires that any use be done in accordance with guidance.  Two separate guidance documents were written:

The restricted waste classification system was originally established for disposal in a company owned landfill but is also a requirement prior to foundry sand use.  Restricted wastes includes four categories, Type I to IV, where Type I is the most contaminated and Type IV is the least.  The actual determination is based on use of the TCLP and Neutral Leachate testing (see below).  The TCLP testing measures the leachate concentration of various metals.  The Neutral Leachate testing measures several secondary drinking water constituents.  Facilities with Type III or IV by-products have the greatest number of reuse options available to them.

Although no permits are issued, a waste classification determination must be acquired from the Indiana Department of Environmental Management (IDEM) before reuse activities are implemented.  IDEM has rigorous protocol for obtaining a waste classification.  It it highly recommended that you contact IDEM staff about the waste classification requirements before you conduct any testing. 

What reuse options are acceptable?

Types III and IV can be used as:

  • landfill daily cover*
  • capped embankments;
  • protective cover for landfill leachate collection systems;
  • ground and site barriers;
  • structural fill base (roads, parking lots, construction fill, etc.);
  • a raw material in other manufacturing processes (flowable fill, concrete, asphalt, cement, etc.); and
  • in land application and soil amendments.

*Foundry sand may be used as alternative daily cover at a municipal solid waste landfill under the landfill’s permit.  Waste classification may not be necessary prior to use as alternative daily cover. 

What restrictions apply?

The following thresholds determine the waste type.  Testing is conducted using the RCRA toxicity characteristic leachate procedure (TCLP).

Parameter

Type I Toxicity Characteristic Leachate Thresholds, mg/l

Type II Toxicity Characteristic Leachate Thresholds, mg/l

Type III Toxicity Characteristic Leachate Thresholds, mg/l

Type IV Toxicity Characteristic Leachate Thresholds, mg/l

Arsenic

≤0.05

≤0.50

≤1.3

≤5.0

Barium

≤1.0

≤10.0

≤25.0

≤100

Cadmium

≤0.01

≤0.10

≤0.25

≤1.0

Chromium

≤0.05

≤0.50

≤1.3

≤5.0

Lead

≤0.05

≤0.50

≤1.3

≤5.0

Mercury

≤0.002

≤0.20

≤0.05

≤0.20

Selenium

≤0.01

≤0.10

≤0.25

≤1.0

Silver

≤0.05

≤0.50

≤1.3

≤5.0

Reference: 329 IAC 10-9-4 Restricted Waste Site Criteria.

Neutral Leachate Testing

TABLE 2

Constituents Using the Leaching Method Test
Constituent Concentration (milligrams per liter)
 
Type IV
Type III
Type II
Type I
Barium
1.0
10.0
25.
***
Chlorides
250.
2,500.
6,300.
***
Copper
.25
2.5
6.3
***
Cyanide, total
.20
2.0
5.0
***
Fluoride
1.4
14.0
35.
***
Iron
1.5
15.0
***
***
Manganese
.05
.50
***
***
Nickel
.20
2.0
5.0
***
Phenols
.30
3.0
7.5
***
Sodium
250.
2,500.
6,300.
***
Sulfate
250.
2,500.
6,300.
***
Sulfide, total
1.0
5.0
13.
***
TDS
500.
5,000.
12,500.
***
Zinc
2.5
25.
63.
***

TABLE 3

pH (using the Leaching Method Test)
Constituent Acceptable Range (Standard Units)
  Type IV Type III Type II Type I
pH 6.0-9.0 5.0-10.0 4.0-11.0 ***
         

***Testing is not required.

Do I need a permit?

Indiana does not have a specific permit for sand reuse.  However, you must follow the procedures for waste determination and classification and receive a waste classification from IDEM before reusing sand.

What steps do I need to take to reuse my foundry sand?

A facility must perform:

  • hazardous waste determination and
  • waste classification.

The purpose of the waste determination is to establish that the waste is “non-hazardous” and does not contain PCBs or other wastes regulated by the Toxic Substances Control Act (TSCA) or the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  The waste classification determines whether the used sand is Type I, II, III or IV.

In most cases, the determination/classification can be made by taking representative samples of the used sand (must develop a sampling plan prior to taking samples) and analyzing the samples using the TCLP extraction procedures.  The analytical data is submitted to IDEM for classification.

Once a facility determines that its waste sand is non-hazardous and obtains its waste classification from IDEM, it may use the waste material for any of the approved uses for that category.  No reporting of amounts or types of reuse, or further analysis of end materials is required.

Where can I get testing performed?

List test regional labs.

What reporting and recordkeeping requirements must I meet?

Once a facility determines that its waste sand is non-hazardous and obtains its waste classification, it may use the waste material for any of the approved uses for that category.  No reporting of amounts or types of reuse is required.  Futher testing and loading rate calculations are required for use in land application.  See IDEM guidance for further details.  Those test results and calculations do need to be submitted to IDEM but must be kept onsite and made available to IDEM upon request. 

What other requirements must I meet?

Foundry sand must be properly stored at a facility prior to reuse.  IDEM published guidance on Storage of Type III Foundry Sand Prior to Legitimate Use.  This document identifies applicable rules and restrictions and it outlines procedures for notifying IDEM prior to storing used foundry sand.

More information

Restricted Waste Regulations: Restricted waste is found in Indiana’s Solid Waste Disposal Facilities Rule at 329 IAC 10-9-4.  Restricted waste is waste that is characterized for disposal in a restricted waste site. These are landfills that take industry-specific waste such as foundry waste or coal combustion ashes. This program is also reference for characterization of foundry sands prior to use under Indiana Statute IC 13-19-3-7.

State solid Waste Regulations.  Solid waste rule --- 329 IAC 10.

IDEM Industrial/Special Waste.  This page covers disposal of non-hazardous waste rather than use.   It may be helpful for those looking for disposal requirements. 

State hazardous waste regulations.  Hazardous waste rule --- 329 IAC 3.1.

Responsible waste division: Office of Land Quality.

State agency point of contact: Tracey Kohler,

Applicable case studies: None located.

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