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Ion Exchange Regeneration Facility

 

Q2 I am also planning to start Ion Exchange bottle (3.2 Ft3) regeneration plant for heavy metals like Nickel, Copper, Lead and Chromium for full recovery of metal. I want to determine the market size in California. and also in the nation. How can I conduct this market research.?

Abdullah Kazi
- San Jose, California

After a long conversation with the California state version of the EPA, you will rapidly abandon this as an idea unless you have about 5 million dollars to set up the facility and have all of the hazardous waste licenses.

James Watts
- Navarre, Florida

I don't really know the answer to the marketing question. There are already at least two companies in the business of regenerating ion exchange resins used for wastewater treatment. Since neither advertises here I will not mention their names.

I would suggest, if you haven't already done so, to get a good lawyer and take a close look at the environmental permitting process involved in setting up such a business. Hazardous waste recycling and disposal are heavily regulated. Stories I have heard about getting a TSDF permit say it can take millions of dollars and a couple of years to get properly (legally) set up.

If you are looking for a loophole in the law do do it "on the cheap" as some have done, I think you are crazy and dangerous.

Bill Vins
microwave & cable assemblies - Mesa (what a place-a), Arizona

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The EPA presently considers all exhausted ion exchange resins originating from plating rinse waters that are provided on a service basis to be F006 waste. The ramifications here are numerous, however there is NOT a requirement to have a RCRA B standardized permit to regenerate these at a facility. This is a falsehood. The "waste" has to be transported by a licensed carrier that can lawfully ship the canisters to your facility as RCRA waste, however once it gets there, what happens to it is another story.

The importance here of "final resting place" for the metals cannot be understated. ALL of it must go to a reprocessing reclamation facility - nothing can go to a landfill, secure or not. This normally allows you to operate under an exclusion rule for recycling facilities. The issue of the millions of dollars for permits is untrue, and it is perfectly legal. An important caveat here is that you CANNOT, under any circumstances, allow non-regenerated bottles to sit for any extended time period, or you will need to have a TSDF permit. The EPA considers the activity of recycling to begin upon introduction of the recyclable material into the recycling unit. (ß261.6(c)(2)) Therefore, resins must be sent into the resin float reasonably upon delivery to the facility. At that point, they are considered in process.

ALL metals must be removed from solutions and treated within that timeframe. All reclaimed metal sludge must be removed within some period of time as well, and must be set to a reclaim facility, which should return a certificate of reclamation within 30 days of receipt. The EPA has taken a hands off approach on the derivative mixture rules for wastes as far as the treated and neutralized water goes - and it is usually treated and discharged to the local sewer without need for a 29 CFR 413 or 467 based permit. You will, however, need a local permit - and perhaps a state permit as necessary.

There are restrictions that will apply - no water or other solution may be in the vessels at the time of receipt at the facility (and I would assume before they leave the plant!), You may receive no liquid wastes containing metals, such as concentrated baths, etc. You need to have storage permits for the bulk acids and caustic that you will require to conduct operations. All operators must have OSHA 1910 Hazwoper training - 40 hrs and annual 8 hr refreshers. Certain metals may present secondary hazard conditions, such as nickel (CA EPA says its carcinogenic), cadmium, etc.

Most of all, paperwork is a must, and you must follow all applicable RCRA documentation guidelines as far as the manifests required for transportation and receipt of the material.

The previous is the current EPA position as far as I know, however state and local regulations may differ or be more severe than the EPA's.

The last thing is that the EPA is seriously considering the elimination of the F006 designation for exhausted resins. They are looking at the potential for a separate designation (for tracking and compliance purposes) that would be exempt from the F series rules, but allow them to see where reclaimed materials go. Its a response to the industry, and it could happen as soon as 1-2 years.

Tom Baker
wastewater treatment specialist - Warminster, Pennsylvania

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What you say is true for Ohio, but I doubt if all of California goes along with that. Since resin must be shipped "damp" or it will crack, how does that go with the "absolutely no water"?

James Watts
- Navarre, Florida

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There is a significant difference between "damp" and freely flowing water. Ion exchange resins are damp (hydrated) when they are delivered to you from the factory. As the IX vessels are essentially closed, it is almost impossible to have them dry out in transit (how far are you shipping them?) Also, only some type of external influence, such as extreme heat or such, would drive the water from resins during this time.

Many things make resins crack - and drying out is not necessarily one of them, unless they are subjected to mechanical shock in that form. Resins can be completely dried and then rehydrated with no damage, but this is not the point here.

California MAY have a different slant on this - but on the other hand there is strong precedent from the Federal EPA for a variance in the matter. As most state's that are authorized to administer the Federal rules, they typically very closely model their own laws on them so they do not have to be placed in opposition of double compliance enforcement.

Ohio is one, so is Tennessee, so is Illinois, and even Florida, which has 2 metals reclaiming companies using IX without a TSDF or RCRA B standardized permit. As always, the proof is in the pudding - if you have a clean record and operation, then you are much more likely to have a successful experience with regulators than that of one cloaked under suspicion.

Tom Baker
wastewater treatment specialist - Warminster, Pennsylvania