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Environmental Management Alternatives

Utilization of Commercial Byproducts in Place of Virgin Chemicals

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Utilization of commercial byproducts in place of virgin chemicals

Question #1 Is it legal? YES

Question #2 Will I save money? YES

Question #3 Will you help me? YES

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When it started

The Resource Conservation & Recovery Act (RCRA)

In 1976 Congress passed the Resource Conservation Recovery Act which directed the United States Environmental Protection Agency (EPA) to develop and implement a program to protect human health and the environment from improper hazardous waste management practices. The program was designed to control the management of hazardous waste from its generation to its ultimate disposal from its “cradle-to-grave”.

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Four Major Programs

Congress outlined four major programs in RCRA:

• Solid Waste (Subtitle D) — focuses on nonhazardous solid waste, such as municipal garbage and industrial waste not classified as hazardous waste

• Hazardous Waste (Subtitle C) — required by EPA to develop and manage a nationwide program that identifies wastes that are hazardous and set standards for safely managing this waste from the moment it is generated, through storage, transportation, recycling, treatment, and ultimate disposal.

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Four Major Programs

• Medical Waste (Subtitle J) — focusing on the management of infectious waste.

• Underground Storage Tanks UST (Subtitle I) — required by EPA to set standards for the operation and design of USTs to prevent leaks into the ground.

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Definitions

• Generator — is any person, by site, whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation under EPA (40CFR 260.10)

• EPA ID # — this number, issued by the US Environmental Protection Agency, identifies each handler of hazardous waste on hazardous waste manifests and other paperwork. The ID # enables regulators to track waste from its “cradle to grave”.

• Manifest — the documentation of tracking your waste from cradle to grave.

• TSDF (Treatment Storage & Disposal Facility) — managed the wastes that generators produced.

• Commercial and Chemical — made from industry.

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Byproduct definition

a. a product made during the manufacture of something else

b. a secondary or incidental product deriving from a manufacturing process. This material can be useful and marketable.

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Byproduct definition

c. RCRA definition

By-products are secondary materials subject to RCRA regulation

as solid wastes unless, as you note, they are recycled by being

“(i) used or reused as ingredients in an industrial process to

make a product, provided the materials are not being reclaimed;

(ii) used or reused as effective chemical substitutes for

commercial products; or (iii) returned to the original process from

which they are generated without first being reclaimed” 40 CFR

Section 261.2(e) (1). Also, by-products that are hazardous only

because they exhibit a hazardous characteristic are not solid

wastes when reclaimed (40 CFR Section 261.2(c) (3)).

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Byproduct definition continued…

A by-product is defined in RCRA as "a material that is not one of the primary products of a production process and is not solely or separately produced by the production process" (40 CFR Section 261.1(c) (3)). The preamble to the 1985 Definition of Solid Waste final rule provides clarification of the Environmental Protection Agency's (EPA's) intent regarding what constitutes a by-product. It explains that EPA means to include as by products, "materials, generally of a residual character, that are not produced intentionally or separately, and that are unfit for end use without substantial processing" (50 FR 625, January 4, 1985).

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Examples of RCRA Definition

• Examples

• hydrochloric acid byproduct from chemical manufacturing used by the steel industry in pickling steel;

• sodium hydroxide byproduct from chemical milling of aluminum and aluminum extrusion operations.

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Understanding the market

Under EPA-regulated waste minimization goals, generators try to manage waste materials responsibly while following the government’s request to reduce, reuse and recycle.

Every time a waste manifest is signed, the generator must exhaust this resource of reducing, reusing and recycling that material per EPA.

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Understanding the market

Unfortunately, there is minimal support for that line of business called recycling. TSDF's are typically the only option for waste generators. TSDF's have one goal in mind, for you to send them your waste so they can process the material and increase their revenue. Seldom do they offer the waste generator, an option to find a reuse for any byproduct or hazardous waste stream and remove the generator out of the hazardous waste cycle.

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Where are we now?

As virgin materials became more expensive and scarce, byproduct chemicals became more attractive for utilization. Our society generates billions of pounds of byproducts everyday which are commonly destined for hazardous waste disposal through TSDF’s. Experience and knowledge regarding the proper use of these chemicals vary from material to material as well as from state to state. To properly recover these materials for potential beneficial reuse, everyone from the generator to the regulators need to be aware of the properties of the materials, how they can be utilized, and what if any limitations may be associated with their use.

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Advantages of commercial byproducts

1. Protects our scarce natural resources

2. Avoid environmental hazards

3. Reduces our nation’s reliance on raw materials & energy

4. Reduces your costs for products purchased

5. Avoid disposal costs

6. Safe recycling of hazardous waste helps to meet corporate

environmental stewardship policies and goals, promoting

environmental success to preserve an environmentally friendly

reputation or as an environmental leader in their sector.

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How to get started utilizing commercial byproducts

1. Supply customer with Certificate of Analysis (CofA) and or copy of analysis from a certified laboratory.

2. Material Safety Data Sheet (MSDS)

3. Origin of byproduct — supplier should give you a general description of the material and its industrial origin and current supply of subject material.

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How to get started utilizing commercial byproducts

4. Environmental Considerations—make sure your supplier provides a description of the potential environmental issues related to the use of the specific material for all applications. (should be provided in the MSDS). For instance alum caustic is an excellent source for ph adjustment but can also have superior qualities in the removal of phosphates in a waste water treatment system.

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How to get started utilizing commercial byproducts

5. Documentation of Claims—Supplier should provide proof that the material is being used in a production process of that there is a known market for the material. Having contract in place is another good example of documentation of claim.

6. Testimonials—regulatory approval of the program and other byproducts that are currently being purchased for an equivalent application.

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Reducing your environmental footprint

Companies and organizations around the globe are desperately seeking to reduce their global environmental footprint. Many of them are achieving this by:

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Reducing your environmental footprint

1. Meeting their waste minimization goals

RCRA required facilities that generate or manage

hazardous waste to certify that they have a waste

minimization program in place that reduces the

quantity and toxicity of hazardous waste

generated to the extent economically practicable.

In 1990 Congress passed the Pollution Prevention

Act and expanded waste prevention policy

beyond RCRA.

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Reducing your environmental footprint

2. ISO 14001 certification

Manufacturing practices for environmental responsibility and sustainability. Prevention of pollution is linked to your environmental objectives. Anytime someone has an opportunity to change their waste classification to recycling, this is considered an effective OFI (Opportunity for Improvement). Continuance improvement is a must within any ISO system.

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Reducing your environmental footprint

3. Green Initiatives

Reducing operating costs through energy conservation and reducing the impact on the climate through reduced water, reduced internet technology server power consumption, utilizing wind energy as alternative power sources, reduced energy consumption per location, reduced speed motors, modified temperature sensors, installing sky lights, and turning off equipment when not and use, etc.

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Contact EMA today

Environmental Management Alternatives

info@ema-env.com

(314) 785-6425