"To improve is to change; to be perfect is to change often.” — Winston Churchill
Unlike any other time in history, the ability to build in flexibility and make adjustments quickly and without interruption to a company’s daily operations is key to sustained profitability. This is particularly true when it comes to the disposal of hazardous waste. For many years, and especially during the past two decades, general industry has been virtually unrestricted on its ability to dispose of the hazardous materials that result from its varied manufacturing and production processes. This is not the case today.
The EPA implemented the Land Disposal Restrictions (LDR) over an 11-year period in the United States from 1986 to 1997. In years prior to the current LDR, industry benefitted from the ability to use Subtitle C landfills for the majority of its K listed wastes. Once enacted, the LDR regulations eliminated the ability for refineries to dispose of their waste in the quantities and methodologies of the past. Because of this, industry in the United States turned to Canada for similar landfill disposal options just as they used previously in the United States. In January 2008, Environment Canada adopted very similar LDR regulations to that of the United States adding yet another blow to the status quo of hazardous waste disposal. The landfill option disappeared.
In order for any company to survive, it must be willing to change. In order for any company to sustain its profitability, it must have operational flexibility. One of the emerging methodologies for companies to remain flexible in difficult economic times is to have multiple disposal options for their hazardous materials. Having a multitiered plan for waste handling and disposal represents a paradigm shift from the past. As waste treatment technologies and hazardous waste management regulations evolve, so too do the economics of hazardous waste management. Unlike years past when there was a glut of disposal options and “incineration slots” were more numerous than inbound loads of material, today’s waste marketplace is just the opposite. American industry has had to resort to committing more effort and resources into its waste management programs by adopting waste minimization strategies, material substitution programs (where environmentally friendly compounds replace hazardous ones) and alternative treatment technologies.
One of the ways the petroleum refining industry is achieving operational flexibility for waste disposal is through the use of RCRA-permitted cement kilns. For many years, cement kilns have received solvent-based wastes that were high in both Btu value and solids content. It has not been until recently petroleum refiners have begun to utilize these same outlets for their hazardous material disposal. Higher hazardous waste incineration prices and limited disposal capacity are just two of the driving forces behind this change. While federal regulations require 99.99 percent of the material put into both incinerators and cement kilns must be thermally destroyed, the similarities stop there. Cement kilns burn at a higher operating temperature than hazardous waste incinerators and the material detention times are significantly longer. The ash from hazardous waste incinerators must be treated as hazardous waste and is disposed of in a Subtitle C landfill where the Comprehensive Environmental Response, Compensation and Liability Act regulations still apply to generators of hazardous waste. Conversely, kiln dust is sold as a nonhazardous product on the open market. The ability for cement kilns to burn refinery waste as slurry versus traditional dewatered or solidified material also represents significant economic savings in the area of on-site waste processing.
These changes in the marketplace could not have come at a better time as the manufacturing sector that once was the main source of the waste fuels for cement kilns has seen a drastic decline since the downturn in the economy. Simultaneously, the cement kilns have been active in changing their abilities to receive both high percent solids in liquids as well as adding the capacity to accept solids. They have also been forced to upgrade their air emission equipment as air quality standards tighten. This opportunity presents the perfect storm for those in need of disposal of waste solids, especially since landfills are no longer an option and other outlets such as incinerators are often full and only offer higher priced disposal alternatives.
President Barack Obama said, “Change will not come if we wait for some other person or some other time. We are the ones we’ve been waiting for. We are the change that we seek.” From an environmental management perspective, it seems the president was right. There is a change in the air; all we need to do is think outside of our comfort zone and embrace it.
For more information, visit www.stcindustrial.com or call (713) 504-0414.
