“But it’s our job to try to sell everything our plants produce every day. Trying to find uses for materials that don’t necessarily meet specifications is a big challenge.” – Cheri Miller, market development specialist at TVA
“NEARLY EVERY industrial process, from manufacturing consumer goods, to generating energy, produces many different types of usable materials. These industrial materials can be recycled just like newspapers—both are valuable commodities.” – EPA’s Industrial Material’s Recycling Website
Recycling or reusing some byproducts may make sense, but only when the material in question will not result in greater harm through its reuse. Industrial wastes are generated in massive quantities in the U.S. — some by large coal-fired power plants, and some by smaller businesses that produce relatively high-volume waste (like foundries). There’s no doubt that these wastes are an indication of unsustainability of our system, and that we should aim to reduce virgin material consumption through source reduction and reuse whenever we can – safely. But what about all the industrial wastes that are untested, unquantified, lack quality controls, go unlabeled, etc.? Unfortunately, in a rush to promote so-called beneficial use of these industrial byproducts, industries and regulators are skipping some important product testing and risk management and quality control stages.
Standards for some materials do exist — but these standards are mostly engineering standards, not environmental or human health risk management plans. For example, Foundry Industry Recycling Starts Today (FIRST) <http://foundryrecycling.org/> includes examples on their website of foundry sand applications in highway construction. Compaction and moisture content recommendations are given, but there is no mention of which foundry sands might be unsafe… what about leaching of contaminants from the foundry sands, or degradation through use or construction projects on the road base…. what additional precautions should be taken when handling this material versus the usual material? How will workers be advised of potential hazards from contact?
EPA’s website for industrial waste recycling includes a footnote stating that some foundry sands are often characteristically hazardous and are not included in EPA’s goals for reuse and recycling of industrial byproducts. However, EPA keeps this as a footnote on a page that otherwise is all about extolling the virtues of recycling industrial wastes. EPA needs to be more clear about the types of waste that may not be safe in these applications, and the public will need to be vigilant about industrial waste recycling projects to ensure that additional and unnecessary hazardous wastes are not added to roads, used as soil amendments, or added to cement kiln raw materials or concrete products.
USDA is currently exploring benefits and risks of using waste foundry sand in agricultural and horticultural applications. In the meantime, hazardous foundry sands may be lumped into categories with all foundry sands when people casually discuss the issue <http://www.afsinc.org/pdfs/Final_Beneficial_Reuse_Guide.pdf>.
When any environmental testing is recommended in this arena, it is usually limited to the TCLP test. The TCLP test simulates engineered landfill conditions and is designed to determine if certain listed contaminants identified by US EPA are present in landfill leachate. This test may be appropriate for characterizing the waste in an engineered landfill, but it is not a sufficient safety test to determine other exposure risks from inhaling, handling, or trace element volatilization from industrial byproducts. Communities and project engineers will need to be careful when determining appropriate and safe uses for industrial byproducts if they are going to bring them into contact with people or food. We cannot just listen to the industry line on this one, and unfortunately, we can’t count on EPA to keep the facts transparent here either. We need to keep the pressure on EPA and industries to demonstrate the safety of their projects, or else to keep their industrial waste out of places where we might come into contact with it. Wikipedia defines the precautionary principle as “a moral and political principle that states if an action or policy might cause severe or irreversible harm to the public, then in the absence of a scientific consensus that harm would not ensue, the burden of proof falls on those who would advocate taking the action.” We should encourage EPA to follow a precautionary principle approach to applications/uses of these wastes. Let’s err on the side of caution and make sure that we don’t let the real testing of these waste applications happen in a manner that is irreversibly harmful to humans and the environment.
Sources for quotes:
http://www.eei.org/magazine/editorial_content/nonav_stories/2003-07-01-ccp.htm
http://www.epa.gov/epaoswer/osw/conserve/resources/ind-mat.htm
