Key Concepts and Definitions

What is Foundry Sand?

Foundry sand is a high-quality silica sand used by metal casting facilities to make molds for shaping molten metal into parts. After repeated use, the sand becomes "spent" and needs to be replaced - creating a large volume of by-product material.

What is Beneficial Reuse?

Beneficial reuse means finding safe, productive ways to repurpose industrial by-products (like foundry sand) instead of throwing them away. It protects the environment, saves natural resources, and cuts disposal costs. In Arkansas, beneficial reuse helps businesses lower expenses and communities build infrastructure more sustainably.

Examples of beneficial reuse for foundry sand include

Replacing mined sand in concrete or road base
Using sand as daily cover at landfills
Mixing into manufactured soils for landscaping

What is a TCLP Test?

TCLP stands for Toxicity Characteristic Leaching Procedure - a laboratory test required by the U.S. EPA to find out if a waste material might release harmful contaminants into groundwater.

How a TCLP test works

A sample of the material is soaked in a mild acidic solution that simulates rainwater or landfill conditions.
Scientists measure what chemicals "leach out" of the sample into the fluid.
If dangerous levels of metals (like lead) or chemicals are found, the material is classified as hazardous waste and must be managed under strict regulations.

If the material passes the TCLP test (meaning contaminants are below federal limits), it can be reused safely under environmental rules.

Why Should Readers Care About Foundry Sand Reuse?

Environmental Protection: Reuse reduces waste sent to landfills and conserves natural sand resources, which are expensive and limited.
Cost Savings: Foundries, cities, and contractors save money by reusing sand instead of buying new materials or paying high disposal fees.
Public Safety: Proper testing (like TCLP) ensures that reused sand does not threaten drinking water, soil, or the environment.
Economic Growth: Reuse projects create jobs, strengthen recycling industries, and make local construction and public works projects more affordable.

Regulatory Guidelines

Arkansas Department of Environmental Quality Regulations

The Arkansas Department of Environmental Quality (ADEQ), now part of the Department of Energy and Environment, regulates beneficial reuse through Regulation 22: Solid Waste Management and Arkansas Code § 8-6-606.

Beneficial Use Requirements

Foundry sand for beneficial reuse requires a case-by-case evaluation by ADEQ
Applicants must provide certification from a qualified professional demonstrating the material will have no negative environmental impact
TCLP testing or equivalent toxicity analysis is required to verify non-hazardous status

Alternative Daily Cover

Under Regulation 22.413(b) and 22.512, alternative cover materials (other than six inches of earthen cover) may be used at landfills if approved by the Director and determined to control vectors, odors, litter, and fires without environmental impact.

Arkansas Landfill Disposal Fees: Under Arkansas Code § 8-6-606, landfill disposal fees are:

$1.50 per ton (weight basis) or $0.45 per compacted cubic yard
$0.25 per uncompacted cubic yard
Private industry landfills: $0.50 per ton or $0.20 per compacted cubic yard

Note: Arkansas does not have a specific fee exemption for foundry sand used as landfill daily cover, unlike some other states.

Contact: For beneficial use determination inquiries, contact the Arkansas Division of Environmental Quality, Office of Land Resources, Solid Waste Management Division.

Federal EPA Guidelines

At the national level, the U.S. EPA encourages the reuse of spent foundry sands from iron, steel, and aluminum foundries. EPA's major documents include:

Risk Assessment for Spent Foundry Sands in Soil-Related Applications (2014)
Sustainable Materials Management Program resources.

EPA concluded that silica-based sands from iron, steel, and aluminum foundries can be safely reused in soil blends, construction materials, and road bases.

EPA does not federally regulate beneficial reuse of non-hazardous foundry sands but defers regulatory authority to states like Arkansas.

Local Ordinances

Arkansas does not have a statewide municipal permitting framework for foundry sand beneficial reuse. Local requirements vary by city and county. Projects must comply with state ADEQ regulations (Regulation 22) and may be subject to additional local permits or approvals depending on the project location and scope. For specific requirements, contact the relevant city or county environmental or planning department and ADEQ.

Reuse Applications and Arkansas Examples

Beneficial reuse of foundry sand takes multiple forms depending on material properties and regulatory approvals. Common applications documented nationally include landfill daily cover, road base and fill, and cement/concrete production.

Common Beneficial Reuses
Reuse Application	Description
Landfill Uses	Alternative daily cover, drainage layers, and cell construction material. Foundry sand is approved in most states as alternative daily cover material under certain conditions.
Road Base & Fill	Substitute for sand/aggregate in road subbase, embankments, and structural fill. EPA supports use as a foundation layer for roads (subbase).
Cement & Concrete Production	Raw feedstock in Portland cement kilns or as fine aggregate in concrete. EPA estimates approximately 2.6 million tons of spent foundry sand is beneficially used annually in the U.S., with cement/concrete applications among the highest-volume uses.
Manufactured Soil	Blended into topsoil or manufactured soil products to improve drainage. EPA risk assessment supports this use at concentrations up to 50% for silica-based sands.
Asphalt & Pavement	Used in hot mix asphalt and controlled low-strength material (flowable fill).

Examples in Action

Cement Kiln Reuse: Holcim’s Mason City plant processes ~75,000 tons/year of spent foundry sand. Sourced regionally, including from Iowa foundries, this reuse saves virgin resources and cuts emissions.
Road Construction Fill: Foundry sands have been used in highway projects for structural fill under roads (e.g., projects near airports and industrial parks across the region).
Landfill Daily Cover: Dubuque landfill and Scott County landfill actively accept foundry sand, saving money and conserving native soils.
Potential Soil Amendments: Pilot projects (especially from EPA studies) show blending foundry sand into topsoil improves drainage without heavy metal uptake by plants.
Sandblasting and Niche Uses: Core sands have been diverted for industrial sandblasting jobs, substituting for more expensive commercial blasting media.

Environmental and Technical Considerations

Beneficial reuse of foundry sand requires careful understanding of material composition, contaminant risks, and environmental testing protocols to ensure safe and responsible outcomes.

Types of Foundry Sands

Ferrous Foundry Sands (Iron and Steel Castings)

Typically high-purity silica sand bonded with clay (green sand) or chemical resins.
Low in contaminants.
EPA and ADEQ consider these the safest and most preferred for reuse.

Non-Ferrous Foundry Sands (Aluminum, Brass, Bronze Castings)

Similar base sand but potential contamination from metal alloys.
Brass/Bronze sands often contain elevated lead, requiring more stringent testing or stabilization before reuse.

Specialty Sands

Some foundries use olivine sands or other media; not covered under EPA’s standard risk assessment for reuse.
May alter soil pH or chemistry.

Contaminants of Concern
Contaminant	Source	Notes
Lead (Pb)	Brass/bronze alloys	Key concern; must not exceed TCLP leaching limit (5.0 mg/L).
Chromium (Cr)	Stainless steel alloys, pigments	Usually low and stable in ferrous foundries; not a major issue.
Phenols / Cresols	Phenolic resins (binder breakdown)	Organic compounds typically present in very low concentrations.
PAHs	Burnt sea coal or resin residues	Detected at very low levels; below environmental risk thresholds.
Dust / Free Silica	Physical hazard from dry sand	Requires dust suppression measures during handling to protect workers.
pH / Salinity	Binders, chemical additives	Some foundry sands have slightly alkaline pH, generally not problematic unless used directly in soils.

Importance of TCLP Testing

The Toxicity Characteristic Leaching Procedure (TCLP) is the industry-standard EPA test to determine whether foundry sand poses a leaching hazard to groundwater.

Simulates landfill leachate conditions using an acetic acid solution.
Measures 8 key metals (Lead, Arsenic, Cadmium, Chromium, etc.).
Passing TCLP = Sand is classified as non-hazardous.
Ferrous foundry sands in Arkansas typically pass TCLP easily.

If foundry sand fails TCLP (e.g., high lead from brass castings)

It must be managed as hazardous waste, not reused without treatment.

Key for Arkansas Reuse

For beneficial use approval in Arkansas, applicants must provide:

Certification from a qualified soil scientist or professional demonstrating the material has beneficial use and will have no potential short or long-term environmental impacts
Analytical testing showing constituent concentrations (the guidance does not specifically mandate TCLP; it requires analytical results showing what compounds are present and their concentrations)
Beneficial Use Plan addressing storage, transportation, application, equipment, buffer zones, and site-specific details
Supporting documentation for all proposed land application sites

Note: Arkansas ADEQ guidance requires analytical testing to demonstrate safety but does not specifically mandate TCLP testing as the sole or required test for foundry sand beneficial use approval.

Environmental Behavior of Foundry Sand

Heavy metals in ferrous sands are generally immobilized in the sand matrix.
Organics (e.g., phenols, PAHs) are below actionable risk levels according to EPA risk assessments.
Field studies show low leachability and no significant uptake into plants when used in soil amendments.

Conclusion: For properly characterized ferrous foundry sands, environmental risks are minimal - supporting broad beneficial reuse.

Funding, Grants, and Incentives

State-Level Incentives

Recycling Distribution Program

Arkansas distributes recycling funds to regional solid waste management districts through an entitlement program based on a statutory formula (formerly the Recycling Grants Program). Each regional solid waste management district determines eligibility and fund allocation within its district. Eligible projects typically include recycling equipment, collection facilities, and educational programs. Contact your local regional solid waste management district for eligibility and application procedures.

E-Waste Grants Program

The Arkansas Department of Energy and Environment (E&E) administers a competitive E-Waste Grants Program providing funding for projects that divert electronics from landfills. Eligible applicants include regional solid waste management boards, cities, counties, schools, and nonprofit organizations. Applications are accepted annually (typically July-September). Approximately $250,000 is available in the current grant cycle.

Alternative Daily Cover Approval

Under Arkansas Regulation 22.413(b) and 22.512, foundry sand may be approved as alternative daily cover material if the Director determines it controls disease vectors, fires, odors, blowing litter, and scavenging without environmental risk. Individual approval is required for each landfill or project.

Landfill Disposal Fees

Arkansas Code § 8-6-606 establishes landfill disposal fees of $0.25-$0.45 per cubic yard (or $1.50/ton on weight basis). Unlike some states, Arkansas does not offer a specific fee exemption or surcharge reduction for foundry sand used as daily cover.
Contact: For state-level funding and grant opportunities, contact the Arkansas Department of Energy and Environment, Division of Environmental Quality, Solid Waste Management Division, or your regional solid waste management district.

Federal-Level Opportunities

EPA Sustainable Materials Management Grants

Periodically available grants supporting innovative reuse/recycling projects.
Can fund pilot projects, outreach campaigns, or infrastructure improvements related to foundry sand.

Federal Infrastructure and Recycling Funding (Infrastructure Investment and Jobs Act)

Some grant programs are open to states and municipalities improving recycling or circular economy initiatives.
Foundry sand reuse aligns with goals of waste reduction and sustainable construction.

FHWA / DOT Support

Federal Highway Administration promotes the use of recycled materials (including foundry sand) in road construction.
Some research grants and technical support available for projects demonstrating new uses of industrial byproducts in infrastructure.

Local Opportunities

Local Government Partnerships

Counties and cities sometimes offer mini-grants or project cost-sharing for green construction and waste diversion projects.
Example: County public works departments may help subsidize trucking costs if foundry sand is used in local road construction.

Public-Private Collaborations

Landfills may waive tipping fees for sand.
Construction contractors may provide free transport in exchange for discounted material.
Informal partnerships often unlock major savings without formal grant applications.

Summary Table: Key Funding and Incentive Programs
Program/Incentive	Type	Key Details	Impact for Foundry Sand Reuse
Recycling Equipment Tax Credit	Tax Incentive	30% state income tax credit for purchase of eligible recycling equipment and installation. Equipment must be used exclusively for collecting, separating, processing, or treating solid waste. Requires ADEQ certification.	Can reduce capital equipment costs (sand reclaimers, screening equipment) by 30%.
Alternative Daily Cover Approval	Regulatory Approval	Foundry sand may be approved as alternative daily cover at landfills under Reg. 22.413(b) and 22.512 if the Director determines it controls vectors, odors, and litter without environmental risk. Individual approval required.	Reduces landfill operational costs; no state fee exemption but may reduce overall disposal expenses through operator agreements.
Solid Waste Infrastructure for Recycling (SWIFR) Grants	Federal Grants	EPA provides grants to states and political subdivisions for post-consumer materials management. Arkansas is eligible. Grants support planning, data collection, and implementation of circular economy strategies. Funding varies by grant round.	May support foundry sand market development, collection infrastructure, or implementation planning.
E-Waste Grants Program	Federal Grants	Competitive grants for diverting electronics from landfills. Approximately $250,000 available annually. Eligible applicants include regional solid waste boards, cities, counties, and nonprofits.	Limited direct applicability to foundry sand; focuses on electronic waste.
Brownfield Assessment Grants	Federal Grants	EPA provides grants for Phase I and Phase II environmental site assessments. Arkansas received $1,000,000 in FY 2024 (Department of Energy & Environment).	Potential application if foundry sand beneficial use projects involve site assessment or remediation.

Active Participants in Arkansas

Foundries (Generators of Spent Sand)

Sloan Valve Company (Augusta, AR)

Brass foundry producing copper-based castings for plumbing, electrical, and industrial applications.
Operates a Class 3N landfill (Permit #0235-SR-1) exclusively for disposal of foundry sand waste.
Produces approximately 60,000 pounds of brass castings per day (CDA 84400 and CDA 83600 semi-red brass).
Uses a Class 3N landfill for sand disposal with lead immobilization treatment for non-ferrous foundry sand.

Steel and Metal Manufacturing

Nucor Steel Arkansas (Armorel, AR)

Electric arc furnace steel plant producing hot-rolled sheet steel for automotive, appliance, and construction applications.
Primary steel producer in Arkansas.

End Users (Potential Consumers of Foundry Sand)

Potential end-use sectors in Arkansas include:

Landfill operators accepting alternative daily cover materials
Cement and concrete manufacturers (though no major cement plants currently operating in Arkansas)
Road construction and infrastructure projects through state and county transportation departments

Supporting Agencies

Arkansas Department of Energy and Environment (E&E)

Division of Environmental Quality, Office of Land Resources, Solid Waste Management Division
Manages beneficial use determinations and regulatory compliance for foundry sand reuse projects

Clear Business Case Summary

Why Foundries Should Reuse Sand

Save $30 - $50 per ton vs. landfill disposal costs.
Avoid environmental liability.
Improve sustainability reporting for customers and regulators.

Why Contractors Should Reuse Sand

Get free or discounted sand for construction fill.
Improve project bids by lowering material costs.

Why Landfills Should Accept Foundry Sand

Secure free cover material.
Reduce operating costs.
Increase daily cover efficiency.

Risk Management Overview

Beneficial reuse of foundry sand carries significant economic and environmental benefits, but participants must manage risk carefully to ensure compliance and protect their businesses.

Best Practices

Testing and Characterization: Submit analytical testing showing constituent concentrations (metals, organics) to demonstrate the material has no potential environmental impacts. ADEQ does not mandate a specific test method; testing requirements are determined on a case-by-case basis.
Documentation: Maintain all analytical results, beneficial use certifications from qualified soil scientists, shipping records, and site-specific approvals. ADEQ requires documentation demonstrating compliance with beneficial use determinations.
Written Agreements: Establish written contracts with receiving facilities (landfills, contractors) specifying approved uses and responsibilities. Beneficial use authorization is facility and application-specific.
Beneficial Use Plan: Submit a detailed plan addressing storage (including liners and runoff controls), transportation, application methods, equipment, buffer zones, property ownership, and site restrictions.
Liability: Beneficial use authorization does not release generators from environmental liability. Unauthorized waste disposal is subject to penalties under Arkansas Code Annotated § 8-6-204 et seq.
Contact: For specific requirements, consult the Arkansas Division of Environmental Quality, Solid Waste Management Division, before implementing any beneficial reuse project.

ARS Support: ARS can assist participants in setting up compliance systems, testing protocols, and document templates to minimize legal risk.

Step-by-Step Workflow for Foundries

Test: Conduct TCLP testing or equivalent on representative sand samples through an accredited laboratory. Confirm results meet ADEQ non-hazardous thresholds.
Document: Save all lab results, including full reports and summary sheets.
Partner: Contact ARS to match your material to a reuse project (landfill, cement, construction).
Agreement: Sign a beneficial reuse agreement or memo of understanding.
Ship: Begin shipping sand as needed. Label loads clearly and maintain load-out logs.
Monitor: If your production process changes (e.g., alloy change, new binder), re-test your sand. Maintain communication with ARS and receiving partners.

Result: Compliance, savings, and sustainability without added operational headaches.

Real Cost Savings Example

Why Reuse Makes Financial Sense

Landfill Disposal Costs

Disposal fee: ~$70-$150/ton
Landfill surcharge: +$4.25/ton
Total = ~$74.25-$154.25/ton to landfill

Beneficial Reuse Costs

Transportation only: ~$10-$75/ton (varies by distance)

Savings Calculation

If your foundry produces 1,000 tons/year:

Landfill cost: 1,000 tons x $49.25 = $49,250
Reuse transport cost (avg $15/ton): 1,000 tons x $15 = $15,000
Total annual savings: ~$34,250

Multiply this by 5 - 10 years and the impact becomes massive.

General FAQ & Landfill-Specific FAQ

Is reused foundry sand safe for public use projects like roads or parks?

Yes, EPA studies conclude that silica-based foundry sand from iron, steel, and aluminum foundries can be safely reused for road base, landfill cover, and similar applications, provided it meets environmental testing requirements and receives ADEQ approval.

How often does foundry sand need to be tested?

Initial testing is required to obtain beneficial use approval. Re-testing is recommended if the foundry changes its metal casting processes, alloys, binders, or raw materials.

Can reused foundry sand be used near homes, gardens, or drinking water supplies?

Uses like road base are approved. For applications in soils near homes, gardens, or drinking water sources, additional case-by-case ADEQ evaluation and environmental assurances are required.

Who is responsible for proving the sand is safe - the foundry or the user?

The foundry (generator) is responsible for testing and certifying that the sand meets environmental requirements. The end user must ensure the sand is used only for ADEQ-approved applications.

What if sand chemistry changes after approval?

Notify ADEQ and re-test if foundry processes change significantly.

Landfill-Specific FAQ

Does foundry sand affect landfill leachate or groundwater?

EPA and USDA studies confirm that properly tested silica-based foundry sand does not contribute hazardous leachate or present groundwater threats. Arkansas groundwater monitoring programs provide additional oversight.

Is foundry sand considered acceptable daily cover material?

Yes, under Arkansas Regulation 22.413(b) and 22.512, foundry sand may be approved as alternative daily cover if the ADEQ Director determines it controls vectors, odors, fires, blowing litter, and scavenging without environmental risk.

Do we need special equipment to handle foundry sand?

No. Standard landfill equipment (dozers, loaders) can handle foundry sand.

Contact: For specific questions about foundry sand safety or approval, contact the Arkansas Division of Environmental Quality, Solid Waste Management Division.

Foundry Sand Reuse in Arkansas