Industrial Process Waste Is the New Feedstock
<< Previous
Waste as the New Feedstock
Waste is something that is no longer useful. But in industrial processing, what was once considered waste is now a feedstock candidate. This is especially true for industries transitioning to lower carbon sources, such as recycling used cooking oil into biofuel. U.S. legislation can complicate industrial efforts to recycle wastes into feedstock for new products and processes. Proper tracking and definition can turn a waste product into a feedstock.
Hazardous and Dangerous Waste Legislation: A Brief
In response to a number of environmental disasters, including haphazard and dangerous waste disposal practices, the U.S. government passed legislation in the 1970s. Included in this spate of environmental regulations was the Resource Conservation and Recovery Act, or
RCRA, passed in 1976. In 1984, the Hazardous and Solid Waste Amendment (
HSWA) changed the requirements of RCRA to encourage the recycling of classified waste. This was a meaningful change in philosophy from treating all classified waste the same to standards based on the actual hazard the waste poses.
Waste to Feedstock
Feedstock is the raw material used in production, usually associated with industrial processes. If the feedstock is raw material, can we consider waste to be a feedstock? The answer is yes, and it is in the details of the definition under RCRA of solid waste. The
EPA excludes certain waste from regulatory requirements through several methods. This includes excluding any classification based on how we reuse or recycle the waste, or by naming it specifically as exempt.
Feedstock by Reuse and Recycle Definition
Legitimate recycling of solid waste can fall into one of the following categories:
- Waste used as an ingredient: This is where the waste product of one process makes it useful directly as an ingredient of a different product without any preprocessing.
- Waste used as a substitute: Often, a waste product is a suitable substitute for an ingredient. This means the original intention of the proposed feedstock was not as an ingredient, but the properties are similar enough to substitute for that original ingredient.
- Waste returned to the production process: This is the classic feedstock where one production process produces the raw material for another by design.
Feedstock by Material Type
The list of materials exempt from solid and hazardous waste regulation when recycled into a feedstock is available
here. The by-type list has a number of caveats that define the circumstances that the waste product can be exempt from RCRA disposal requirements. For example, recovered oil in petrochemical processing can be a feedstock in the refining process if it is considered hazardous because of its ignitability characteristics. As with most of these exemptions, the potential feedstock cannot be speculatively accumulated — it needs to have an actual role in the industrial process.
The second classification under material type has specific exclusions. Under solid waste, this includes agriculture waste, used chlorofluorocarbon refrigerants, used oil filters and distillates intended for asphalt products. Hazardous waste can also be excluded from hazardous waste regulations. An example is scrap metal recycling, which includes batteries and precious metals reclamation.
Define It and Track It: Using Technology to Track Compliance
With RCRA and all waste management, tracking the material and its associated definition are key to managing regulatory compliance. Tracking software is necessary to meet today's regulatory and business climate. Technology, such as the Aegex Feedstock and Compliance Tracking System (
FACTS), enables companies to comply with EPA regulations for tracking volumes and sources of biofuel feedstock.
Your company probably operates in different jurisdictions, which may have various regulatory requirements as well. The software needs to identify waste and potential feedstock based on federal and state requirements. Using technology, such as sensors and electronic bills of lading, instead of a driver's estimate and paper during the collection process, increases the reliability of the volumes and location. Additionally, workers can verify the quality of the source feedstock material. Contact
Aegex Technologies for a demonstration of the FACTS platform.
