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					   Responsible Recycling:
   Enforcement Updates,
     Alerts and BOLAs

                    Lisa Brown
       A s s i st a nt G e n e r a l C o u n s e l
                for Enforcement

                       About me

 Work on coordinating with regulators, investigators
    and prosecutors on environmental enforcement and
    enforcement training
   Representative to the Western States Project
   Chair of the California State Environmental
    Enforcement Task Force
   Co-chair of the California Border Task Force (Mexico
    and California)
   11 years, Dep. DA for San Joaquin County,
    Environmental Crimes Unit
           About the Western States Project

 EPA and member supported non profit that provides
    environmental enforcement training to the western
    United States.
   Members meet twice a year & discuss current
    enforcement issues
   Any government agency that works on
    environmental enforcement may join
   Membership dues vary according to population
       Some information on the web is available to nonmembers
        The Problem: Sham Recycling

 When ―recycling‖ is actually storage without a
  market usually end up as illegal disposal and
 Businesses will set up shop, gather a lot of
  hazardous materials that have no market with no
  value then walk away leaving a mess that is
  expensive to clean up
           Potential Problem Areas

 Used or waste tires
 E(electronic)-waste
   CRT glass

 Alternative fuel production
   Biodiesel

 ―Soil additives‖ that are industrial waste
 Filter cake
           Sham Waste Tire Recycling

 44 million reusable and waste
  tires are generated annually in
 Several companies have
  accumulated large piles then
  walked away
                       E Waste

 Californians discard 3.3 million per year
 CRT plastic has no value and there is concern about
  attempts to import or speculative accumulation
 Leaded CRT glass can be reused but
    processing can create hazardous waste
The Promise
The Reality: ink solids are contaminated with other
inks and solvent and not usable
                   The Reality

 All of the ugly paint and used thinner is
fully regulated as hazardous waste (F003).
 – Need HW labels
 – Containers must be closed
 – Must transfer material from damaged
containers into good containers.
 Criminal case filed (Louisiana).
 See other examples in the handouts
Soil Additives? Or Disposal of Haz Waste?

 Ash
   Bottom, fly, boiler etc

 Ash from cogen plants
 By products from metal production
 By products from food production
 Sewage sludge
 Mining waste
         Hazardous Waste in Fertilizer

 Ironite®, once available at many lawn and garden
  stores, was a common fertilizer made from mine
  tailings. The presence of arsenic and lead in Ironite
  lead to its banning in Canada, and lawsuits in the
  United States
 See
         Hazardous Waste in Fertilizer

 NGOs sued EPA in 1998 for failing to regulate
  hazardous waste in fertilizer as aggressively as it
  does hazardous waste in landfills
 Federal regulations were published in 2002
            Sham Plastics Recycling

From Arizona
 DEQ: Calif.
 claiming that
 plastics were
 being stored
 for future
 recycling - they
 were digging
 trenches and
                     For help

• Market Share: Tips and Advice from the Jobs
 Through Recycling Experience: EPA530-5-99-039

 Tribal Decision-maker's Guide to Solid Waste
 Management: November 2003, EPA530-R-03-013

 Writing Business Plans for Recycling Enterprises:
 Plastics, Glass, or Rubber January 1998 (produced
 under a US EPA grant).
              Checklist from EPA website

   What is the facility's site history and ownership history? Have
    there been any previous activity and/or contamination at the
   Does the facility have a history of environmental compliance?
    Have they been subject to any enforcement actions?
   Is the facility in compliance with all required permits?
   What is the general housekeeping at the facility?
   Does the facility employ responsible practices such as waste
    screening and acceptance procedures, residuals management,
    drop-off and tracking protocol and certificates of recycling?
   Is the facility financially sound? Does it have adequate
    pollution liability insurance and provisions for necessary
    closure and cleanup costs if necessary?
           Examples of Sham Recycling

   Ineffective or only marginally effective for the claimed use -
    e.g., using certain heavy metal sludges in concrete when such
    sludges do not contribute any significant element to the
    concrete's properties.

   Used in excess of the amount necessary - e.g., using materials
    containing chlorine as an ingredient in a process requiring
    chlorine, but in excess of the required chlorine levels.

   Handled in a manner inconsistent with its use as a raw
    material or commercial product substitute - e.g., storing
    materials in a leaking surface impoundment as compared to a
    tank in good condition that is intended for storing raw
    How Do You Screen New Businesses?

 If it sounds too good to be true….
 What is their biz plan?
 Who else does this work?
 Check out their market (who will buy what they are
 Google the names
               Keep an Eye on Them

 Is their storage amount growing?
 Trust but verify
 Be suspicious of facility that refuses entry for
  inspection, vague about business plan, cannot
  identify real customers
 Do not rely on samples the facility takes, take your
  own random samples
 Insist they give you all their sample results, not just
  the ones they chose to send you
                 What you hear….

 Biodiesel fuel is a renewable vehicle fuel produced
  from a variety of the oil of crops or from waste
  cooking oils.
 Reduction in emissions & carbon dioxide
 Highly biodegradable and therefore does not pollute
  soil or waterways should it be spilt.
 EPA press release compares it to table salt (2004)
     Where is It?
Biodiesel Fuel Stations
Commercial biodiesel production
plants         22
             Downsides of Biodiesel…

 Biodiesel may contain small but problematic
    quantities of water.
   Water causes corrosion of fuel system components:
    fuel pumps, injector pumps, fuel lines, etc.
   Biodiesel also effects types of natural rubbers
    found in some older engine components.
   Production process uses hazardous materials and
    produces hazardous by products particularly
    contaminated glycerin
   Production presents severe fire hazards
         Biodiesel Affects on Equipment

―Use of biodiesel at levels above 5% may have a
significant effect on materials, performance or
combustion of some equipment.‖
 Underwriters Laboratories 2009
             What You Don’t Hear…
             The Dangerous Process

• The catalyst, potassium hydroxide or sodium
  hydroxide and methanol solution, splits the
  feedstock into glycerin and bio-diesel.
• The mixture of oil and catalyst is kept just above the
  boiling point of the alcohol for at least 2 hours.
• After the separation of the glycerin and biodiesel
  phases, the excess alcohol is removed by different
       Catalysts: potassium hydroxide

 Corrosive
 Fatal if swallowed
 Burns eyes or skin
 Vapors are harmful
 Reacts to water or acid
(strongly exothermic)
    Catalyst: Methanol

• Toxic
• Inhalation, dermal & oral exposure hazard
• Effects are cumulative
• Highly flammable with a colorless flame
• Flashpoint 55F
• Vapors are heavier than air
• Requires DOT approved labels and
• The National Fire Safety Code limits the
  amount of methanol you can store at a
  residential location to two five gallon

 Is known to cause reproductive toxicity
 Is a candidate for listing based on formal
  identification as causing reproductive toxicity by the
  U.S. EPA and Cal/EPA.
 Colorless flames are a challenge for firefighters
                   Biodiesel Additives

 Antioxidants to stabilize the fuel
   most of which are hazardous substances.

 Biocides and fungicides to reduce microbial activity.
   Without the addition of these hazardous substances, biodiesel
    may oxidize and form peroxides which are also on the OSHA
    Special Health Hazard Substance List because peroxides can
    be highly explosive and mutagenic.
          Home Production of Biodiesel

― This is the first time I have
  ever attempted to build
  anything like this. I am very
  happy that I came across
  the Journey to Forever
   If I, with absolutely NO
  background in chemistry
  can produce a workable
  fully functional
  reactor/wash tank combo
  then anyone with sufficient
  determination can do it.‖
Home Made Garage Units

                 4.22.09 Seattle
                biodiesel from
                used cooking oil
                in his garage.
Biodiesel and Fire Hazards

                  Try this
                  biodiesel and
               What You Hear…

―Ferocious fires and explosions blamed on backyard
  refining operations have been reported in
  Washington state, Arizona, Colorado,
  Massachusetts and Oregon. No deaths or
  serious injuries have resulted, but some fire
  officials say it is only a matter of time. ―
     Worker Fatalities at Biodiesel Facilities

1.   Blue Sky Biodiesel Idaho 2006
2.   San Diego California, 2006
3.   Farmers & Truckers Biodiesel Georgia 2007
4.   Greenlight Biofuels Maryland 2008
5.   Northwest Biodiesel Missouri 2008
6.   Alberta Canada 2008
          California 2008

10 biodiesel production facilities
7 burned down and there was one
 worker death
Biodiesel Fires: Firefighters Perspective

―It was a huge column of black smoke unlike
anything I'd ever seen" said the Canby [Oregon]
Fire Marshal. ―It was so hot that it burned
aluminum and sagged metal."
          Biodiesel Compliance Issues

 No standard MSDS
 Uniform Building Code
    "automotivemotor fuel dispensing facilities‖
 Equipment compatibility:
   Vapor recovery

   USTs

   Dispensing nozzles

 Contaminated by product--glycerin

 EPRCA regulations on hazardous materials storage
 RCRA Hazardous waste re spilled, spent materials

Currently there are no applicable Manufacturing
ELGs or Pretreatment Standards (effluent)
guidelines for this sector. General pretreatment
standards and NPDES regulations still apply.
                Biodiesel and USTs

 Biodiesel has a significant solvent effect which will
 affect storage tanks that previously stored petroleum
 diesel. In addition, biodiesel is susceptible to
 corrosive oxidation and microbial contamination.

 Underwriter Labs have not issued any UST
 compatibility certifications for above B5
                Uniform Fire Code

 Biodiesel (B100) is considered a class II combustible

 Methanol and/or Ethanol are considered more
 hazardous and storage is limited by many
 jurisdictions to two 5 gallon containers similar to
               Uniform Fire Code

 Sodium hydroxide (AKA lye, caustic soda) and/or
 potassium hydroxide (strong base) are considered
 caustics and may be limited to "reasonable"
 quantities as determined by the fire marshal

 Glycerin by product is contaminated/ methanol and
  they try to sell it & it undercuts legitimate recycling
  and sales of pure glycerin;
 19 biod facilities w/in 2 hours north of the
  Canadian/US border
 US Customs has stopped contaminated glycerin at
  the US/Mexico border northbound because importer
  could not establish they had any market for it
EPA website on biodiesel --No mention of production or
storage hazards or regulatory requirements

    Where Do I Find More Information on
        Regulatory Requirements?

 Alternative fuels guidance document at