Can my Hazardous Secondary Materials be applied to the land?

The answer is “yes”.  Environmental professionals often believe that land application is not acceptable for any type of hazardous secondary material (ie. hazardous chemical coproducts, byproducts, or used chemicals), but this is simply not the case.  While RCRA and state regulations do ban land application as “use constituting disposal” for many materials, use of certain hazardous secondary materials in land application IS ACCEPTABLE under certain conditions.   Specifically, if the hazardous secondary material has a corresponding prime chemical that is normally used in such land application then use of the secondary material may be permissible.  the key to success is ensuring that the hazardous secondary material has no “toxics along for the ride” and that it is not a listed waste.  If these criteria can be met, then the material may be able to be used in a land application.  Careful evaluation of the ultimate disposition of each of the potentially hazardous constituents should be made to ensure risks are no different for use of the corresponding prime product.

For a specific example of this type of land application, please see our blog entitled “Can my former sulfuric acid waste be used to make fertilizer?

For more information about this topic, for general questions about beneficial reuse, or for more information about Altiras, please contact Todd Pencarinha at 713-568-3651.

Altiras develops new solution for hazardous secondary materials that cannot be used “as-is”

In accordance with the definition of solid waste, under 40 CFR 261.2(e) Materials are not solid waste when recycled if they are used or reused as ingredients in an industrial process to make a product or as effective substitutes for commercial products, provided the materials are not being reclaimed.  Since these materials cannot be reclaimed or process first, we refer to this as “use as is”.

Altiras Chemicals was founded on the basis of “use as is” use of secondary chemicals (byproducts, coproducts, used, offspec, and surplus chemicals).  If these secondary chemicals contain listed chemicals or have characteristics that, as a waste, would make them hazardous, they may be considered “hazardous secondary materials” by EPA (40 CFR 260.10).  Altiras Chemicals has been very successful in beneficial reuse of hazardous secondary materials when the materials could be used as is.  Unfortunately, there are many of these materials that simply cannot be used as is.  Sometimes the color is too dark, the material might contain other constituents that would cause problems for the intended use, or there may be “toxics along for the ride.”  Because of these issues, many of these materials have continued to be managed and hazardous wastes, even though they may have had very high intrinsic value.

Fortunately, Altiras Recovery has developed solutions for many of these types of products that cannot be used as is.  The solution involves careful coordination with generators of the materials, regulatory authorities, and Altiras’ expertise in RCRA regulations, process development, and product markets.  If you have hazardous secondary materials that have high intrinsic value, but no market value due to some problem constituent or characteristic, please contact Todd Pencarinha at 713-568-3651 or by email at tpencarinha@altiras.com

Guidance for Beneficial Reuse of Non-hazardous Industrial Wastes

When considering the beneficial reuse of non-hazardous secondary materials, the most important factor to consider is whether or not use of the material will have a negative impact on human health or the environment.  EPA provides sound guidance on this subject (linked here), even though many have argued (and won court cases) that EPA has no authority in regulating materials that are not waste.  We will address arguments against EPA’s authority over non-wastes in a different post.  In the present case, whether EPA has authority or not is irrelevant if you care about product stewardship, because good product stewardship mandates this same process.  Considering the potential for negative impact on human health and environment is, by definition, product stewardship.  On this basis, I encourage use of the EPA guidance for beneficial reuse of non-hazardous materials

For more information on this post or Altiras beneficial reuse solutions, please contact Todd Pencarinha at 713-568-3651.

How can a beneficial reuse company ensure quality of products?

Todd Pencarinha, Altiras president, was recently asked “How can a company that buys and sells coproducts, byproducts and used chemicals have any kind of a quality assurance program?” His response was simple – “the same as any other company that provides quality assurance”. Pencarinha elaborated that “quality assurance means maintaining a desired level of quality by paying attention to every stage of the process and establishing procedures whereby one can have confidence in the expected outcome.” He added that the hardest part is in changing the mindset of suppliers, who are not in business to make coproducts, byproducts or used chemicals. Nevertheless, Pencarinha says that analytical testing and statistical processes can be employed to gain the necessary confidence in the outcome – that is the quality of the product.  The company uses a six-sigma approach to quality assurance.  This means extensive statistical product testing and process documentation, which ultimately provides the necessary assurance of quality.

For more information on this article or on Altiras’ quality assurance process, please visit the company’s website at http://www.altiras.com or contact Todd Pencarinha directly at 713-568-3651.