Businesses across the US are increasingly recognizing the benefits of a circular economy to address growing resource constraints– not just the environmental benefits of reducing footprint size, but also the potential cost savings, brand image and risk management benefits.
Due to recent rule changes, it has now become easier for businesses operating in Michigan to find alternatives to the landfill disposal of manufacturing by-products. These recent changes provide industry an opportunity to collaborate across the entire supply chain to reduce waste through diversion and reuse.
Rule Change Impacts Sustainability
Michigan’s recently updated Beneficial Use By-Products Amendments under Part 115 allow more flexibility to divert waste by-products to productive uses. In general, the new rules view wastes as a resource, something corporate sustainability efforts should remain mindful of. Diversion of materials from disposal to reuse can improve a company’s brand and in some cases its bottom line, while off-setting the use of some natural resources for certain purposes. Also, corporate sustainability professionals need to be cognizant of how this fits into their company’s existing Environmental Health & Safety (EHS)/Sustainability/Environmental Management System (EMS) programs, which may require calculation of greenhouse gas emissions, water usage, and other offsets for annual reporting.
Reuse: What and How
A wide range of materials are already designated as Beneficial Use By-Products, such as foundry sand (ferrous and aluminum), coal ash and coal ash bottoms, and cement kiln dust. Through Michigan’s program other materials can now be diverted including:
Materials that are not already designated may be diverted by petitioning the Michigan Department of Environmental Quality (MDEQ) for reuse, where appropriate. A new petition process is under development; in the interim, the Rule 118 method is still used.
Michigan’s revised standard recognizes a number of materials that may be used in one or more of five Beneficial Use Categories, including:
Foundry sand is good example of a material that should be evaluated for reuse, as it potentially qualifies for all five categories. Practical uses include fill material under specified conditions and as cold weather road grit (which may be of interest to local municipalities, as the price of road salt remains high).
Evaluating Potential Reuse
Criteria for qualifying as a beneficial use vary by material and the proposed beneficial use category, but generally starts with the assessment of the by-product. Information necessary to a preliminary reuse evaluation includes source(s) of material, analytical characterization by waste stream, and volume and frequency of by-product generation. For some sources, the volume/frequency of generation may not justify the costs of the full evaluation, or the risks associated with the material being used at an alternate location, but for others the tangible and intangible benefits can be significant.
If appropriate for reuse, finding a partner which can use the by-product in accordance with the rules is next. Activities at this step include (depending upon by-product), petitioning MDEQ for prior approval, additional analysis if needed (e.g. TCLP/SPLP), permitting through MDARD if Beneficial Use 3, documentation of off-site management, assistance with reuse compliance and annual reporting.
Tips for Success
A couple of points to keep in mind while evaluating a potential beneficial reuse:
For additional information, please refer to the MDEQ website for links to rules and guidance.
These changes provide companies with even more flexibility to manage manufacturing residuals in a proactive and sustainable manner. Evaluation of reuse options for beneficial by-products can be a relatively simple process, and production managers, EHS experts and material managers should make this assessment part of their routine operations. TRC’s professionals are adept at evaluating beneficial by-product uses, as well as other sustainability efforts. For assistance with evaluations and developing a proactive approach, please contact TRC, or share your experiences in the comments section below.
Contributors to this blog include Kurt Gerdes, Remediation Market Director, Karen Lutz, Sustainability Director and Graham Crockford, Senior Client Services Manager.