Hazardous Waste Industry
Alot of people ask me what I do for a living..... well, it's complicated. I usually answer that I work for an Environmental Company. True. But most people automatically connect that with Environmental Activism or Ecological Research. Nothing could be further from the truth. You see, I work for a company that manages hazardous waste for disposal. Wow, you might say. Most people think this is a booming industry. But it is actually a shrinking industry. Let explain why.
When Congress created the RCRA (Resource Conservations and Recovery Act) in 1982, and CERCLA (Comprehensive Environmental Response and Compensation Liability Act-Superfund) in the late 70's, the industry did boom for about 5 years until enough startup companies flooded the marketplace. At that time, most companies disposed of their hazardous waste (solvents, acids, bases, contaminated debris, etc.) at landfills. Later in 1988, Congress implemented the First Third Land Disposal Restrictions, which prevented about 80% of the tonage going to landfills from being sent their any longer. This was required because landfill design prior to that date was flawed and many of the solvents placed in the landfills, leached through the unit, through the clay and liner bottom (many early landfills did not even require landfills), and ultimately appeared down gradient in groundwater. By implementing the First Third, Congress mandated treatment technologies and numerical treatment standards for specific waste types. Land disposal was no longer an approved treatment technology for waste streams such as solvents.
Congress gradually implemented the Second and Third Thirds over the next 5 years that further restricted the types of waste going to land disposal facilities. This created a strain on hazardous waste Treatment, Storage and Disposal Facilities (TSDF's) that then were required to more carefully manage wastes accepted from generators of waste to make sure that waste was shipped to a facility that could properly dispose of it. If a TSDF in Phoenix accepted solvent liquids from a aerospace company, they generally had several disposal options for that waste stream. The TSDF rarely actually did the disposal but acted more as a broker for the waste streams they collected from many different industries and generator types. That Phoenix TSDF could elect to sent that waste to a hazardous waste incinerator (there are many in the U.S.), a cement kiln (has fewer emission control requirements than an incinerator), a recycler (solvent must be clean enough to be recycled), or out of the nation (Canada or Mexico). Typically, generators and TSDF's elect the lowest cost option that in the early 80's resulted in many fly-by-night companies popping up that took the money to take these wastes but dumped them on the side of the road or in a ditch rather than disposing as required by regulation.
To address this illegal dumping, Congress created DOT shipping requirements that created chain-of-custody's for every shipment. They also created a cradle-to-grave tracking requirement for generators and TSDF's. Each is required by rule to track their waste from the time they generate it to the time it is disposed. The generator is responsible for that material at every step of the process and thus could be held equally accountable if it ended up in a ditch, having to pay twice for its disposal. This created another new concept in this field - environmental audits.
More later.
When Congress created the RCRA (Resource Conservations and Recovery Act) in 1982, and CERCLA (Comprehensive Environmental Response and Compensation Liability Act-Superfund) in the late 70's, the industry did boom for about 5 years until enough startup companies flooded the marketplace. At that time, most companies disposed of their hazardous waste (solvents, acids, bases, contaminated debris, etc.) at landfills. Later in 1988, Congress implemented the First Third Land Disposal Restrictions, which prevented about 80% of the tonage going to landfills from being sent their any longer. This was required because landfill design prior to that date was flawed and many of the solvents placed in the landfills, leached through the unit, through the clay and liner bottom (many early landfills did not even require landfills), and ultimately appeared down gradient in groundwater. By implementing the First Third, Congress mandated treatment technologies and numerical treatment standards for specific waste types. Land disposal was no longer an approved treatment technology for waste streams such as solvents.
Congress gradually implemented the Second and Third Thirds over the next 5 years that further restricted the types of waste going to land disposal facilities. This created a strain on hazardous waste Treatment, Storage and Disposal Facilities (TSDF's) that then were required to more carefully manage wastes accepted from generators of waste to make sure that waste was shipped to a facility that could properly dispose of it. If a TSDF in Phoenix accepted solvent liquids from a aerospace company, they generally had several disposal options for that waste stream. The TSDF rarely actually did the disposal but acted more as a broker for the waste streams they collected from many different industries and generator types. That Phoenix TSDF could elect to sent that waste to a hazardous waste incinerator (there are many in the U.S.), a cement kiln (has fewer emission control requirements than an incinerator), a recycler (solvent must be clean enough to be recycled), or out of the nation (Canada or Mexico). Typically, generators and TSDF's elect the lowest cost option that in the early 80's resulted in many fly-by-night companies popping up that took the money to take these wastes but dumped them on the side of the road or in a ditch rather than disposing as required by regulation.
To address this illegal dumping, Congress created DOT shipping requirements that created chain-of-custody's for every shipment. They also created a cradle-to-grave tracking requirement for generators and TSDF's. Each is required by rule to track their waste from the time they generate it to the time it is disposed. The generator is responsible for that material at every step of the process and thus could be held equally accountable if it ended up in a ditch, having to pay twice for its disposal. This created another new concept in this field - environmental audits.
More later.
posted by Utah Chris at 8:07 AM
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