Hazardous Waste Opportunities

1
Hazardous Waste Opportunities Challenges

• The Speciality Batch Chemical Environmental Forum
  
• SEPTEMBER 5, 2002
• Bill Turetsky ISP Corporation
• Pat Nevrincean FMC Corporation

2
Overview

• Increasing recycling opportunities by re-defining
  what is considered a solid waste
• Increasing storage time for hazardous waste will
  aid in this effort
• Reducing RCRA burdens benefits small business and
  the environment

3
DSW OVERVIEW

• Present SOCMAs views on NAICS by explaining why
  a 3 digit NAICS code would be better for our
  members
• Make the case for a new RCRA variance procedure

4
4 OPTIONS
Option 1 Off-site Clean Fuels Cost 573 M/YR
Option 4 Future Non-RCRA Part B
Reclamation Profits 270 M/YR NAICS 3251, 3259
Option 2 RCRA Part B Reclamation Cost 1.34
MM/YR
Hazardous Waste Generator NAICS 3254
Sale Recovered THF To Companies with NAICS 3255
Option 3 Off-site Burning In Cement Kiln Cost
758 M/YR
5
PROCESS FLOW DIAGRAM NAIC CODE 3254
Hexane Wet Cake To the Dryer
Cake Wash 1 (DIWATER/THF/IPA/TEA) 44 34
21 2
Mother Liquors/Rinses to Hazardous Waste 1.84 MM
lb/yr 44 H2O 34 THF 21 IPA 2 TEA Salts
Misc Organics

• Centrifuge
• Centrifuge Wet Cake
• Rinse with DIWATER/THF/IPA/TEA
• Rinse with Hexane

Cake Wash 2 Hexane
Hexane Rinse to Hazardous Waste
6
Option 1 - CLEAN FUELS OPTION
7
Option 2 - RCRA PART B RECLAMATION
8
Option 3 - OFF-SITE INCINERATIONAT A CEMENT PLANT

• Transportation
• Disposal Cost 9.5/lb
• 175M/yr
• Lost THF Value 564M/yr
• Net Cost 739M/yr

9
Option 4 - RECLAMATION AT NON- RCRA SITE
10
DSW CONCLUSION

• A 3 digit NAICS Code would be better for our
  industry.

11
Hazardous Waste Storage

• Hazardous waste generator can currently
  accumulate waste for 90 days or less without a
  permit
• Based on the premise that in most industries, 90
  day limit is adequate, but not disruptive of
  manufacturing process

12
Challenges with 90-days

• 90-day limit is often disruptive to the
  commercial chemical process for specialty batch
  industry
• Smaller/varying volumes of waste generation
• Facility unable to regularly anticipate upcoming
  waste streams
• As a result, companies are often forced to ship
  partial loads but still pay full price

13
Benefits of 180-days

• Increased flexibility in how and when wastes were
  shipped
• Full loads maximize efficiency
• Fewer shipments reduced chance of on-road
  incident
• Fewer shipments less paperwork burden for EPA,
  TSD and generating facility staff
• Increased time to store secondary materials prior
  to recovery
• Ensure enough time to collect amount that is
  economically viable for recycling

14
Burden Reduction

• RCRA regulations initially designed to rely
  heavily on documentation, recordkeeping,
  reporting
• Now that program is more mature, EPA should
  review what documentation still has value
• SOCMA supports RCRA burden reduction proposed
  rule

15
Comments on Burden Reduction

• Self-implementing program to reduce
  tank/container inspection frequency
• Eliminate duplicative requirements
• Reduce record retention times
• Streamline LDR paperwork requirements
• Allow broader qualification requirements for
  certification