CE/Geol/ChE 174 Hazardous Materials Waste Minimization Christopher Vais vaisc@eorm.com 510-610-3396 http://www.engr.sjsu.edu/~jennimi/Classes/CHE174/

Waste Minimization What is waste minimization? Waste minimization refers to the use of source reduction and/or environmentally sound recycling methods prior to energy recovery, treatment or disposal of waste. Waste minimization does not include any process designed to change the physical, chemical or biological composition of waste streams

Waste Minimization USEPA’s Preferred hierarchal approach to materials management: 1. Source Reduction 2. Recycling 3. Energy /Recovery 4. Treatment 5. Disposal

Source Reduction Commonly knows as pollution prevention: 1. Reduces or eliminates the generation of waste at the source And 2. Refers to any practice that reduces the use of hazardous materials in the production process

Source Reduction Common Examples: Early retirement of equipment such as mercury – containing devices like switches and thermostats; Reformulating or redesigning products, such as creating new PVC compounds without using lead; Using less toxic feedstocks, such as switching to the use of lead-free solder in manufacturing; Improving work practices, such as reorganizing paint batches in order to reduce cleaning operations.

Recycling Recycling includes the reuse or recovery of in-process materials or materials generated as by-products that can be processed further on-site or sent offsite to reclaim value. Recycling is a broad term that encompasses the reuse of materials in original or changed forms rather than discarding them as wastes. Recycling can also be thought of as the collection and reprocessing of a resource so it can be used again, though not necessarily for its original purpose.

Recycling Common Examples: Direct use/reuse of a waste in a process to make a product, such as reusing a purge product used to clean paint lines rather than disposing of it by incineration. Processing the waste to recover or regenerate a usable product, such as collecting vapor from drycleaning operations, turning it back into liquid, and reusing the liquid to clean more clothes. Using/reusing waste as a substitute for a commercial product. When mercury is recycled from old equipment like switches, it can be used in new products that still require mercury, such as fluorescent bulbs. Recycling of mercury has been so successful that there is now enough recycled mercury in the U.S. that manufacturers do not need to use new mercury from mines.

Energy Recovery Gasification converts carbon-containing materials, under high temperature and pressure, into synthesis gas. Synthesis gas or syngas is generally composed of hydrogen and carbon monoxide but can be manufactured to contain methane and other higher molecular weight compounds. Syngas can be used as a fuel to generate electricity or as a basic chemical building block for use in the petrochemical and refining industries. Syngas generally has a heating value that is approximately two-thirds that of natural gas and, when burned as fuel, produces emissions that are similar to natural gas. In the petroleum refining industry alone, about seven to ten million tons of hazardous byproducts containing carbon, currently managed under the Resource Conservation and Recovery Act (RCRA), could be converted into useable fuel or chemicals using gasification methods.

Benefits of Waste Minimization Waste minimization not only protects the environment; it also makes good economic and business sense. For example, reducing waste generation through waste minimization has helped some companies change their RCRA regulatory status from large quantity generator (1000 or more kilograms of hazardous waste generated per month) to small quantity generator (between 100 and 1000 kg of hazardous waste generated per month), or to conditionally exempt small quantity generator (up to 100 kg of hazardous waste generated per month). Some have managed to eliminate the generation of hazardous waste and avoid RCRA regulatory requirements altogether.

Benefits of Waste Minimization Source reduction and/or environmentally sound recycling, reuse, and reclamation practices have helped many organizations reduce: The quantity and toxicity of hazardous and solid waste generation Raw material and product losses Raw material purchase costs Waste management recordkeeping and paperwork burden Waste management costs Workplace accidents and worker exposure Compliance violations Environmental liability

Benefits of Waste Minimization At the same time, waste minimization can improve: Production efficiency Profits Good neighbor image Product quality Environmental performance

What is Pollution Prevention? Pollution Prevention, often called P2, means source reduction, or preventing pollution at its source, before it is generated. It includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include: equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.

What is the difference between Waste Minimization and Pollution Prevention Waste Minimization is a term found in the Resource Conservation and Recovery Act (RCRA) that refers to source reduction and environmentally sound recycling of RCRA hazardous waste.  Pollution Prevention is a term found in the Pollution Prevention Act of 1990 that refers to source reduction of all toxic wastes, including those released to air, water and land resources.

Source Reduction Source reduction includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include: equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.

Environmentally Sound Recycling Includes the use, reuse and/or reclamation of residuals that may be designated as a hazardous waste, or materials in a hazardous waste. A material is "used or reused" if it is used as an ingredient in an industrial process to make a product or, or if it is used as an effective substitute for a commercial product. A material is "reclaimed" if it is processed to recover a usable product, or if it is regenerated.

Is Waste Minimization Required by Law? In 1984, amendments to RCRA established the following national policy, making waste minimization the nation's preferred hazardous waste management practice: "...the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment." (RCRA Sec.1003[b], 1984.)

RCRA Requirements for Waste Minimization RCRA requires 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.

Pollution Prevention Act of 1990 Passage of the Pollution Prevention Act expanded the nation's waste prevention policy beyond a RCRA-only framework, to minimizing or eliminating toxic releases to all environmental media and natural resources: "The Congress hereby declares it to be the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner." (PPA, Section 6602[b].) The Pollution Prevention Act has encouraged many organizations to expand their focus from RCRA-only to a multimedia pollution prevention focus. EPA offers a variety of information sources on multimedia pollution prevention.

Waste Minimization in California

Hazardous Waste Source Reduction and Management Review Act of 1989 Also referred to as Senate Bill 14 or SB 14 Requires hazardous waste generators subject to the Hazardous Waste Control Law to consider source reduction as the preferred method of managing hazardous waste.

Hazardous Waste Source Reduction and Management Review Act of 1989 Who is affected To determine if your operation must comply with the source reduction planning requirements, ask yourself the following questions: Did my facility generate 12,000 kg/yr or more of hazardous waste or 12 kg/yr or more of extremely hazardous waste in 2014? Is this waste routinely generated from ongoing operations? (One-time waste streams such as demolition debris from decommissioning a production line are excluded.) Does my business generate aqueous hazardous waste that undergoes on-site treatment prior to discharge to the sewer? (If you produce over 3,100 gallons/yr you are captured by SB 14.) If you answer yes to questions 1 and 2, or yes to question 3, you are subject to the SB 14 planning requirements, which include a plan, report and a summary progress report.

Hazardous Waste Source Reduction and Management Review Act of 1989 SB 14 requires the preparation of waste minimization documents every four years for those facilities that meet the waste generation thresholds in the reporting year. Generators are required to prepare three documents. The first document is the Hazardous Waste Source Reduction Evaluation Review and Plan (Plan). The Plan is a forward-looking document in which a generator evaluates potential source reduction/waste minimization measures for each “major” waste stream (waste streams that constitute greater than 5% of the total waste generated). The second document is the Hazardous Waste Management Performance Report (Report) and is a backward-looking document that must assess the effect of each source reduction measure implemented since the baseline year (i.e. 1998) on waste generation. The third document, the Summary Progress Report (SPR), consists of two tables and a comment page that summarizes the results of past waste minimization measures and any new waste minimization opportunities that will be implemented in the next four years.

How to Develop an Effective Waste Management Program Obtain Management Commitment and Organize Teams Management support demonstrates organizational commitment to goals and can help reduce the tendency for employees to disregard procedural changes. Divide Facility into Logical Areas and Identify Raw Materials and Wastes (Materials Accounting) Waste and resource mapping will determine the quantity and locations where raw materials are used, along with the quantities and locations of waste generation. This information can help design waste out of the manufacturing process.

How to Develop an Effective Waste Management Program Identify Full Spectrum of Operating Costs (Environmental Cost Accounting) Environmental cost accounting helps companies calculate the overall impacts of their products and processes. This information can serve as a baseline to measure progress towards goals and cost savings after the waste minimization program is implemented. Establish Goals and Priorities and Develop a Waste Management Plan The waste minimization plan will become a more useful tool if it is framed within the context of facility-specific waste goals. These should be established before the waste minimization plan is developed, with input from senior management and employees, to ensure that priorities are aligned. The collaborative formulation of goals and priorities ensures that a waste minimization plan is an effective roadmap.

How to Develop an Effective Waste Management Program Implement the Waste Management Plan and Follow Up on Recommendations/Implement Continuous Improvement Finally, the plan should be implemented at the facility. Soliciting feedback and recommendations for improvement helps guarantee that the waste minimization plan is as effective as possible, while engaging employees and demonstrating how their expertise is valued. Striving to continuously improve the waste minimization plan will keep manufacturers a step ahead of their competition.