Recovering Spent Precious Metal Catalysts: Environmental and Legal ConsiderationsRecovering Spent Precious Metal Catalysts: Environmental and Legal ConsiderationsBy: Richard DeSantis
This article discusses the legal implications of reclaiming precious metals from spent process catalysts, and suggests methods on how to select a precious metals refiner to avoid legal problems. It also presents a typical case study.
Precious metal catalysts are widely used in pharmaceutical manufacturing processes. For example, heterogeneous palladium on carbon, platinum on carbon, palladium on alumina and palladium on calcium carbonate catalysts facilitate hydrogenation of various intermediates.
Virtually all pharmaceutical manufacturers use fixed-bed reaction catalysts. Most (if not all) of these organizations depend upon precious metals refiners to reclaim gold, silver, platinum, palladium, rhodium, ruthenium, and other valuable metals from their spent catalysts. Precious metals also may be recovered from many process by-products such as filter cakes, papers or cloths, polishing filters, floor sweepings, and protective clothing worn by plant personnel. However, many pharmaceutical companies may not be aware of the legal implications involved concerning effluent or atmospheric discharges at the refiners they select. Bristol-Myers Squibb is one organization that has addressed this concern.
Bristol-Myers Squibb uses chemical catalysts in many of its manufacturing processes. One of the company’s facilities Syracuse, NY uses 4% palladium on carbon catalysts in a hydrogeneration reaction during the production of a fermentation-based penicillin product. This process generates spent palladium carbon cake which is collected and forwarded for recovery to Sabin Metal Corporation, a precious metal refiner located in Scottsville, NY near Rochester. After the residual palladium metal is extracted from the carbon cake, it is transferred to a catalyst manufacturer for fabrication into new catalyst.
In 1996, the Syracuse facility received the New York State Governor's Award for Pollution Prevention. The award recognized the site's overall commitment to environmental leadership. The facility also was presented with the Industry Achievement Award, which is sponsored by the Central Chapter of the New York State Water Environment Association.
Enhancing profitability through the recovery of precious metals from spent catalysts is not Bristol-Myers Squibb's primary concern. Its people are keenly aware of the environmental issues involved in the reclamation process; the company demands that its vendors comply with all appropriate Environmental Protection Agency (EPA) guidelines and regulations.
For this reason, Bristol-Myers Squibb chose a precious metals refiner that operates a "zero discharge" facility. This means that no wastewater is emitted before, during, or after the refining process. Air quality is controlled using advanced pollution control systems which filter 555,000 cu. ft. of air per minute. Process water (the most common source of pollution) is evaporated and residues are reprocessed. Material leaving the plant is limited to refined precious metals and a glass-like borate slag. By using a "zero discharge" refiner, the company minimizes environmental liability.
When asked if different catalyst materials will be used as new pharmaceutical production procedures are developed, Patrick Smith of Bristol-Myers Squibb answered "Speaking for the Syracuse site, we do have a development facility here as well as manufacturing and they may occasionally use rhodium or ruthenium based catalyst, although Bristol-Myers Squibb has the opportunity to use any catalyst as new products enter the pipeline." Recovery procedures—and therefore environmental concerns—would be similar for other precious metals used as catalysts, he added.
The precious metals refining industry does not enjoy an especially sterling reputation with regard to environmental responsibility. When selecting a refiner, be aware not only of how your materials will be processed, but those of the refiner’s other customers as well. Determine how any solid, liquid, or gaseous by-product is handled at the facility.
Requesting documentation also may help you determine that the refiner you select does not violate any applicable environmental law or regulation. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), also known as the Superfund Act, addresses the joint customer/refiner responsibility. This law mandates that both the company which is the source of the material for precious metal recovery and the precious metal refiner share in the "cradle to grave" responsibility as well as the future liability for the proper treatment of the material. Essentially, the environment must be protected to avoid serious financial and legal consequences: your refiner's violation of these laws or regulations could result in heavy fines and legal costs to you.
The Defense Reutilization and Marketing Service (DRMS) of the US Government is charged with the task of disposing of excess property of the Department of Defense (DOD). This program includes many functions, one of which is the recovery of precious metals from obsolete electronic equipment (i.e., instrumentation, computers, etc.). In the past, DRMS has attempted to accomplish this objective by using a number of contractors without first verifying their environmental approval status. This lack of due diligence has resulted in the U.S. Environmental Protection Agency (EPA) assessing DRMS third party cleanup costs in excess of $22 million under the CERCLA.
An excellent way to determine if a facility meets these criteria is to look for the effective utilization of sophisticated technology such as afterburners, baghouses, wet scrubbers, and liquid effluent neutralizing equipment. Also, evaluate the refiner's approval status with local, state, and federal agencies. A precious metal refiner should be willing to furnish copies of all required documentation. These include permits under the Clean Air and Clean Water Acts and proof whether the company qualifies as a bonafide precious metal refiner as specified in the preamble to the Boiler and Industrial Furnace (BIF) rule, and its amendments.
Ideally, your goal is to select a "zero discharge" refiner: one that does not produce any effluent or hazardous waste by-products.
To ensure that your relationship with a precious metals refiner will be mutually profitable and based upon trust and fair treatment, you must address several key questions. Does it use state-of-the-art techniques and equipment for measuring the precious metals content of the materials to be reclaimed? Does it enjoy a long track record and a good reputation within the industry? Who are the refiner's other customers and can you obtain references? Does it have the financial resources to pay you in a timely manner?
You also should carefully evaluate the processing methods the refiner uses for reclaiming precious metals. To ensure maximum "yield," look for a refiner that maintains a modern, well-equipped analytical laboratory. The ideal facility would be one that uses classic volumetric, gravimetric, and fire assay techniques, advanced X-ray fluorescence equipment, atomic absorption, and Inductively Coupled Plasma (ICP) emission spectroscopy. These techniques have been approved by the American Bureau of Standards and by the New York Metal Exchange/Commodities Exchange (NYMEX/COMEX). When used together, they provide the most exacting methods for determining precious metal content in spent materials, thus assuring you the highest possible returns.
Choose a refiner that has significant in-house capability and does not rely on subcontractors. The more it costs your refiner to process your materials, the less your overall return will be. Depending upon the specific precious metal bearing recyclable material to be reclaimed, refiners generally use a combination of pyro-metallurgical and hydrometallurgical processes to achieve the highest possible metal recovery at the lowest possible cost.
Most refiners use a wide variety of equipment and procedures to process spent catalysts. These include rotary and crucible furnaces, kilns, roasters, thermal processors, pulverizers, granulators, screens, blenders, auto samplers, reactors, dissolvers, precipitators, electrolytic cells, and filter presses. In many cases, how this equipment is employed may have a bearing on the percentage of precious metals recovered from spent catalysts and also on the refiner's discharge policies. Don't hesitate to ask questions.
To cultivate trust, the refiner you select should be willing to provide you with detailed weight and analysis reports on your shipments. The most advanced laboratories typically assay sample materials in triplicate to assure precise precious metal measurements. A reputable organization will allow you to be present during the sampling of your materials and will permit you to conduct your own independent analysis if so desired.
Doing your own due diligence before you select a refiner will reduce the likelihood of problems down the road. And remember, whether you like it or not you are a "partner" of your precious metals refiner—at least that's how the EPA may see it.
Richard DeSantis has been the Assistant to the President of Sabin Metal Corporation for five years. His career in the industry has spanned more than 30 years, and includes extensive experience in recovering precious metals from spent catalysts, and related by-products.
Sabin Metal Corp., 300 Pantigo Place, Suite 102, East Hampton, NY 11937; telephone: 631-329-1717; Web site: www.sabinmetal.com
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