Industrial Waste - Chapter 9

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Texas Environmental Almanac, Chapter 9, Industrial Waste, Page 4

INDUSTRIAL CHOICES: HIERARCHIES OF INDUSTRIAL SOLID WASTE MANAGEMENT

As in the case of municipal solid waste, Texas and the EPA have created a hierarchy or a set of priorities for how best to manage industrial solid waste, whether non-hazardous or hazardous.(64) In decreasing order of preference, these priorities are:

Source Reduction;
Reuse or Recycling of Waste;
Treatment to Neutralize Hazardous Characteristics;
Treatment to Reduce Hazardous Characteristics;
Underground Injection; and
Land Disposal.

Thus, never producing the waste is the top priority while land disposal is the least preferred alternative. Each of the methods used to dispose of waste presents challenges for the environment and human health. These challenges are reviewed in the remainder of the chapter.

Source Reduction and Waste Minimization

The best means to get rid of waste is to reduce the amount generated at the source, a process known as source reduction. Waste minimization activities such as reusing and recycling seek to return the waste stream into a production process or alternative use, thus leading to both economic and environmental benefits.

The source reduction and waste minimization approach - often called pollution prevention - has become popular in recent years. Traditional approaches to managing waste have relied on regulatory measures like RCRA, which set up management techniques to control waste at the "end-of-the-pipe." But these technologies are not fail-safe. Pollution may still occur. For example, studies showed that even the best clay-lined landfills eventually may fail and pollute groundwater.(65) Newer plastic-lined landfills have experienced similar problems.(66) And accidents may happen. Furthermore, using an incineration plant rather than a landfill just results in toxics being released into the air instead of the ground. Finally, public opposition to siting almost any type of hazardous waste commercial facility has significantly increased the costs and resources to build such facilities.(67)

The pollution prevention approaches emphasize reducing the environmental and financial costs associated with managing hazardous waste. Pollution prevention is based on two concepts:

The production of waste results in both loss of energy from the production process and loss of valuable resources; and
Once the waste is produced, money, manpower, and additional materials must be spent to manage the waste.(68)

DEFINITIONS AND APPROACHES TO WASTE REDUCTION
Source Reduction as applied by Texas law means reducing the amount of any hazardous or non-hazardous substance entering any waste stream or released into the environment prior to recycling, treatment and/or disposal; Waste Minimization means a practice that reduces the environmental or health hazards associated with hazardous waste, pollutants or contaminants. Examples may include reuse, recycling, neutralization and detoxification. Source Separation keeps hazardous waste from non-hazardous waste, preventing all the waste from being managed as hazardous waste. It does not necessarily reduce the total volume of waste, only its hazardous components. Recycling and Re-use is the process of removing a substance from a waste and returning it to productive use. Recycling can happen at a plant, where the waste is re-used within the production process itself. Waste can also be recovered off-site. A third form of recycling is to send the waste to another industry through an inter-industry exchange. The most common materials recycled in Texas are used solvents, zinc and other metals and acids. Substitution of Raw Materials replaces a raw material that results in hazardous waste with one that results in less hazardous waste or none at all. Manufacturing Process Changes consist of either eliminating a process that produces waste or changing the process so that a waste is no longer produced. Substitution of Products means eliminating the use of a hazardous material. For example, by substituting creosote-preserved wood posts with concrete posts, no hazardous waste will leach from the posts.
Source: Environmental Protection Agency, Solving the Hazardous Waste Problem: EPA's RCRA Program (Washington, DC: EPA, November 1986), 19; and Texas Water Commission, Case Studies of Source Reduction & Waste Minimization by Texas Industries (Austin: TWC, March 1992).

DEFINITIONS AND APPROACHES TO WASTE REDUCTION

Source Reduction as applied by Texas law means reducing the amount of any hazardous or non-hazardous substance entering any waste stream or released into the environment prior to recycling, treatment and/or disposal;

Waste Minimization means a practice that reduces the environmental or health hazards associated with hazardous waste, pollutants or contaminants. Examples may include reuse, recycling, neutralization and detoxification.

Source Separation keeps hazardous waste from non-hazardous waste, preventing all the waste from being managed as hazardous waste. It does not necessarily reduce the total volume of waste, only its hazardous components.

Recycling and Re-use is the process of removing a substance from a waste and returning it to productive use. Recycling can happen at a plant, where the waste is re-used within the production process itself. Waste can also be recovered off-site.

A third form of recycling is to send the waste to another industry through an inter-industry exchange. The most common materials recycled in Texas are used solvents, zinc and other metals and acids.

Substitution of Raw Materials replaces a raw material that results in hazardous waste with one that results in less hazardous waste or none at all.

Manufacturing Process Changes consist of either eliminating a process that produces waste or changing the process so that a waste is no longer produced.

Substitution of Products means eliminating the use of a hazardous material. For example, by substituting creosote-preserved wood posts with concrete posts, no hazardous waste will leach from the posts.

Source: Environmental Protection Agency, Solving the Hazardous Waste Problem: EPA's RCRA Program (Washington, DC: EPA, November 1986), 19; and Texas Water Commission, Case Studies of Source Reduction & Waste Minimization by Texas Industries (Austin: TWC, March 1992).

Hazardous Waste Reduction Programs in Texas

Texas has relied on voluntary programs to encourage source reduction activities. These programs include:

Waste Reduction Policy Act of 1991. This act requires that facilities that generate more than 100 kilograms a month of hazardous waste or that release toxic chemicals under the Toxics Release Inventory Program develop: 1) a waste minimization and source reduction plan; 2) an executive summary of the plan which must be available for public viewing; and 3) an annual progress report.
By 1997, an estimated 10,000 companies must submit source reduction and waste minimization plans to the TNRCC.(69) The largest 600 companies have already presented their plans, projecting that more than 36 millions tons of hazardous waste will not be generated by 1997 because of source reduction.(70) While companies are required to submit the plans, how they choose to reduce pollution, and whether in fact they do at all, is strictly voluntary.
Texas Clean Industries 2000. This voluntary program was begun in 1992. Industries which join this program commit to carry out a plan to reduce hazardous or toxic waste by 50 percent from 1987 levels by the year 2000.
As of March, 1995, 132 companies had joined the Texas Clean Industries 2000 program. Membership includes 29 of the top 50 hazardous waste generators. According to the TNRCC, these industries have pledged to reduce their 1987 levels of hazardous waste by 57 percent by the year 2000.(71) This amounts to pledged reductions of 29 million tons of hazardous waste (or more than 20 percent of total hazardous waste generation). Participants have also pledged reductions in toxic releases to air, land and water by 64 percent, or 268 million pounds.(72) If program participants do not successfully meet their goals, there is no penalty except for potentially being removed from the program. However, according to preliminary data, between 1992 and 1993, program participants did reduce hazardous waste generation by 11.5 million tons and toxic releases and transfers by 36 million pounds.(73)
In 1993, the state's voters approved a constitutional amendment known as Proposition Two, which grants property tax exemptions for pollution control equipment. The TNRCC is charged with implementing this program, which will allow companies installing pollution control equipment or making manufacturing process changes to submit an application to take this equipment off the tax rolls. One of the purposes of Proposition Two is to encourage voluntary source reduction programs through tax incentives (see box).
Through its Office of Pollution Prevention and Recycling, the TNRCC has instituted a variety of other source reduction and waste minimization programs including:
More than 100 pollution prevention workshops to assist companies and local governments in developing recycling and source reduction plans.
Site assistance visits by environmental engineers and other specialistics from the TNRCC to assist companies in addressing environmental problems. According to the TNRCC, 31 Texas facilities have received this technical assistance.(74)
Trans/Mexico Border Program to help U.S. and Mexican companies operating in northern Mexico reduce pollution and increase recycling. In 1993 and 1994, TNRCC personnel conducted site assessments at 10 U.S.-owned factories in Mexico.

POLLUTION CONTROL TAXES IN TEXAS
In 1993, the Texas State Legislature and voters of Texas approved a constitutional amendment known as Proposition 2. This measure allows new property and equipment used for pollution control to be moved off the tax roles. With such a property-tax exemption, the state gives an incentive for companies to meet and in some cases go beyond environmental rules, regulations or statutes. Under rules adopted in 1994 to implement Proposition 2, companies can apply to the Texas Natural Resource Conservation Commission to have pollution control property - a facility, device, or method used to control, reduce, measure or prevent pollution - designated as such. Once such a positive determination is made, the company would then qualify for a property-tax exemption from the local tax assessor. The property must have been installed after January 1, 1994, thus keeping on the tax rolls any pollution control equipment previously subject to property taxes. Examples of new equipment eligible for a Proposition 2 exemption include a scrubber put on an industrial smokestack to meet rules under the Federal Clean Air Act; a dechlorination system in an industry's wastewater plant; or even a change in an industry's production process to prevent the release of a toxic chemical. Supporters of Proposition 2 - which included both small and large businesses and some environmental groups - say the measure will promote voluntary compliance with environmental regulations while preserving jobs as the costs of doing business are lessened. Thirty-three other states offer similar incentives to businesses, and supporters argued that without the measure, industries might prefer locating in another state.(77) Finally, many felt the proposal is fair since not having an exemption would put a financial burden on companies, forcing them both to add often expensive equipment because of federal and state regulations, as well as paying taxes on that equipment. Opponents, including some state environmental groups as well as local tax assessor associations, fear the proposal will result in a massive giveaway of property tax revenue to large corporations. Ultimately, they point out the tax breaks will be at the expense of local school districts, cities and special districts, particularly in the most industrialized areas of the state, such as Harris County, Jefferson County, Dallas/Fort Worth, Corpus Christi and El Paso. While environmental regu-lations can sometimes be costly, opponents of Proposition 2 argued that the law gives every business a tax break to comply with environmental laws, whether or not the business has demonstrated any economic hardship. Thus, opponents maintained that keeping the environment clean is quite simply a cost of doing business, and businesses should not be given incentives to merely comply with the law. In the program's first year, TNRCC approved 752 requests from companies to have their pollution control certified for a total of $1.1 billion dollars.(78) Provided their local tax assessors concur with the valuation, industry in Texas will not have to pay property taxes on this equipment.

POLLUTION CONTROL TAXES IN TEXAS

In 1993, the Texas State Legislature and voters of Texas approved a constitutional amendment known as Proposition 2. This measure allows new property and equipment used for pollution control to be moved off the tax roles. With such a property-tax exemption, the state gives an incentive for companies to meet and in some cases go beyond environmental rules, regulations or statutes.

Under rules adopted in 1994 to implement Proposition 2, companies can apply to the Texas Natural Resource Conservation Commission to have pollution control property - a facility, device, or method used to control, reduce, measure or prevent pollution - designated as such. Once such a positive determination is made, the company would then qualify for a property-tax exemption from the local tax assessor. The property must have been installed after January 1, 1994, thus keeping on the tax rolls any pollution control equipment previously subject to property taxes. Examples of new equipment eligible for a Proposition 2 exemption include a scrubber put on an industrial smokestack to meet rules under the Federal Clean Air Act; a dechlorination system in an industry's wastewater plant; or even a change in an industry's production process to prevent the release of a toxic chemical.

Supporters of Proposition 2 - which included both small and large businesses and some environmental groups - say the measure will promote voluntary compliance with environmental regulations while preserving jobs as the costs of doing business are lessened. Thirty-three other states offer similar incentives to businesses, and supporters argued that without the measure, industries might prefer locating in another state.(77) Finally, many felt the proposal is fair since not having an exemption would put a financial burden on companies, forcing them both to add often expensive equipment because of federal and state regulations, as well as paying taxes on that equipment.

Opponents, including some state environmental groups as well as local tax assessor associations, fear the proposal will result in a massive giveaway of property tax revenue to large corporations. Ultimately, they point out the tax breaks will be at the expense of local school districts, cities and special districts, particularly in the most industrialized areas of the state, such as Harris County, Jefferson County, Dallas/Fort Worth, Corpus

Christi and El Paso. While environmental regu-lations can sometimes be costly, opponents of Proposition 2 argued that the law gives every business a tax break to comply with environmental laws, whether or not the business has demonstrated any economic hardship. Thus, opponents maintained that keeping the environment clean is quite simply a cost of doing business, and businesses should not be given incentives to merely comply with the law.

In the program's first year, TNRCC approved 752 requests from companies to have their pollution control certified for a total of $1.1 billion dollars.(78) Provided their local tax assessors concur with the valuation, industry in Texas will not have to pay property taxes on this equipment.

Recycling and Reuse of Hazardous Waste

A variety of industrial waste can be recycled for use as products. There are three ways in which industrial waste recycling occurs: at the facility itself (on-site recycling), at commercial facilities which gather waste streams from several companies (off-site recycling), and when the waste products from one company are used as inputs in the production process of another company. In 1991, for example, some 232,700 tons of hazardous waste were recycled on-site by major industries in Texas or at commercial recycling facilities. About 13 percent of all Texas-generated hazardous waste treated at commercial facilities was recycled in 1991.(75)

Most industrial recycling of hazardous waste involves three types of processes: solvent recovery; metals recovery; and other organic chemical recovery (including waste oil recovery and non-solvent organic recovery). The state has projected there will be a deficit in commercial capacity for some types of metal recovery such as mercury and zinc in 1995.(76) In fact, in 1991, there were no zinc recovery facilities in Texas, while some 57,400 tons of zinc and zinc-constituent hazardous waste were exported to Mexico for recycling.(79)

Off-site recycling of some hazardous materials is difficult because of the dangerous nature of the chemicals themselves. Unlike some municipal waste such as aluminum which are fairly easy to recycle, some hazardous chemicals are prone to ignite and be reactive. In addition, the fear that industries have of accidents and spills during transportation or recycling operations - and the resulting liability - can sometimes present an obstacle to the recycling of hazardous materials off-site.(80)

Transportation costs to move a waste to another company for recycling purposes are another obstacle. For many products, it is far simpler to dispose of the waste on-site than to exchange it with another company or recycle it.

There is also considerable debate about just what recycling is. Under Texas' Waste Reduction Policy Act, companies that burn their hazardous waste for energy recovery in boilers and industrial furnaces can count the waste as "recycled."

This approach has been criticized by some environmental groups who argue that using waste as fuel is really a method of disposal and pollution is often created in the burning of hazardous waste. In the Clean Texas Program, companies can meet part of their 50 percent reduction goal by burning waste to recover energy on-site; however, companies can not burn waste off-site in cement kilns or other off-site "waste-to-energy" plants to meet their reduction goals.

There are several key aspects of the Texas program for recycling of hazardous waste:

In 1987, the Legislature created the Resource Exchange Network for Eliminating Waste (RENEW). This program aids in the recycling of waste by matching companies that have commodities, by-products, surplus materials or waste with other businesses that can use these same materials as process inputs. RENEW, run by the TNRCC, serves as an information clearinghouse, classifying waste by categories. In 1990, RENEW helped 14 companies disposing industrial solid waste negotiate a transfer to those using them for production, for a total of 416 tons.(81) In Fiscal Year 1993, RENEW helped negotiate 23 transfers of industrial solid waste, totaling 202,291 tons.(82) In all, 140 exchanges have been made, saving $679,000 in disposal costs.(83)

In addition, the Office of Pollution Prevention and Recycling at TNRCC has assisted companies with on-site visits and workshops to push for recycling as well as source reduction. A special focus has been helping businesses develop in-house recycling programs.

Innovative Technology: Neutralizing and Destroying Hazardous Characteristics of Hazardous Waste

A variety of new and emerging technologies can neutralize and, in some cases, even destroy the hazardous characteristics of industrial waste. One new encouraging technology is known as supercritical water oxidation. The process is simple, but expensive. Water is heated, pressurized and mixed with organic compounds, which dissolve. Later, oxygen gas is added to the mix and harmful substances are burned away. What's left is harmless. This gigantic pressure cooker, unfortunately, is very expensive, although a team at the University of Texas at Austin has developed a working water oxidizer.(84)

Other technologies currently being used in the Texas market include:

Bio-remediation. This process uses microorganisms bred to have an appetite for hydrocarbons to "eat" oil spills. One firm in Texas has also developed a strain of bacteria that has also demonstrated success consuming heavy metals.(85)
Carbon adsorption. This is a process in which toxic substances adhere to a specially treated carbon surface.
Dechlorination. This process chemically replaces chlorine with hydrogen or hydroxide ions, leaving chlorinated substances non-toxic.
Neutralization. This process either makes an acid substance less so by adding alkaline substances, or makes a basic substance more acidic by adding acid.
Oxidation. This process adds oxygen to substances such as sulfurs, phenols or cyanides, rendering them non-hazardous.
Precipitation. This process separates solids from a liquid waste so that the solid portion can be managed more safely.
Vitrification. This refers to any process which uses electricity to encase products in glass. For example, electric currents can be introduced into contaminated soils at such high voltages that the soil "turns" to glass.

TONS OF TEXAS HAZARDOUS WASTE RECYCLED, 1991

TOTAL: 232,700 TONS

Note: Solvent, zinc, nonsolvent organic and other treatment and recovery are accomplished at commercial recovery facilities. This chart does not include waste products that are sold or exchanged to another company for use in its production process.

Source: Texas Water Commission, Trends in Texas Hazardous Waste Management (Austin: TWC, July 1993), Table 1 and 4.

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