Utilization of Commercial Byproducts in Place of Virgin Chemicals

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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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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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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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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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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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

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Utilization of Commercial Byproducts in Place of Virgin Chemicals

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