Materials Characterization Paper 

In Support of the 

Proposed Rulemaking – 

Identification of Nonhazardous Secondary Materials That Are Solid Waste 

Scrap Plastics 

March 18, 2010

================================================================== 

1. Definition of Scrap Plastics 

Scrap plastics under consideration here comprise three categories of material: scrap material 

from the manufacturing of plastic items, off-specification (off-spec) manufactured plastic goods, 

and packaging materials used in shipments to industrial users - typically plastic film, pallets, and 

“peanuts.” 

2. Annual Quantities of Scrap Plastics Generated and Used 

(1) Sectors that generate scrap plastics: 

Industrial scrap plastics are generated from the manufacturing of plastic products and 

packaging, and from off-spec manufactured material. 

• Plastic manufacturers (NAICS 325211) are responsible for generating various 

plastic resins that are then combined and molded into products. This sector is 

responsible for plastic production; generators reuse the vast majority of their 

manufacturing byproducts. It is efficient to rework this material back into 

industrial processes (OECD 2006 p.88). The efficiency stems from the fact that 

process scrap is typically made up of single-type plastic. However, even scrap 

from multi-layer food packaging can be reworked into the original process 

provided that food contamination is limited (Robertson 2005, p.26). 

• Data on the generation of scrap plastics are not readily available, but the largest 

market for the use of virgin plastic resins is packaging. Packaging (NAICS 

32611) accounted for 33 percent of plastic industry sales in 2007 (ACC 2008a). 

• The second largest industrial market for virgin plastic, at 21 percent, is the 

manufacture of consumer products (NAICS 31-33) (ACC 2008a). 

• The third and final substantial industry using plastic is building and construction 

(NAICS code 23), with 17 percent of the market (ACC 2008a). PVC in particular 

is used primarily in plastic pipes (NAICS 32612) (Ernes & Griffin, 1996, p.180).

(2) Quantities of Scrap Plastics Generated: The Plastics Industry Producers’ Statistics 

Group reports that the plastics industry in North America produced approximately 

46.4 million tons of thermoplastics in 2007. Polypropylene makes up the largest 

share of virgin plastic production at approximately 9.7 million tons. PVC is the only 

halogenated plastic with substantial production in 2007, with 7.3 million tons (ACC 

2008c). Data from the Netherlands suggest that the plastic processing industry is 

approximately 95 percent efficient, as measured by the ratio of plastic scrap generated 

to plastic material input (Joosten, et al, 2000, p.154). Assuming U.S. plastic 

processors are similarly efficient, the volume of plastic scrap generated would be 
Scrap Plastics 

approximately 2.4 million tons. Exhibit 1 lists the annual quantities of virgin plastic 

generated in 2007 for each type of plastic. 

Data are not available on specific users and volumes of plastic scrap. One source 

suggests, however, that 75 to 90 percent of plastic scrap from production of plastic 

products in the United States in the early 1990s was recycled due to the efficiency 

with which manufacturers can reuse single polymer uncontaminated scrap in their 

production processes (OECD 2006 p.88). A representative of Holcim Group Support 

Ltd. reports that some scrap plastic – typically off-spec products – is obtained through 

direct agreements between specific producers and cement kilns for fuel, but sources 

and quantities of plastics used are considered competitive information throughout the 

industry (Guerra 2008). In addition, the combustor survey database developed by 

EPA for the 2009 proposal of the Commercial and Industrial Solid Waste Incinerator 

(CISWI) standards and the Industrial Boilers Maximum Achievable Control 

Technology (MACT) standards indicates that the sources surveyed for these rules 

annually combust 39,000 tons of material characterized as plastics.1

Exhibit 1: Overview of Plastic Production in North America for 2007 

Plastic Type 

Annual Quantity 

Generated 

(tons) 

Low-density polyethylene (LDPE) 4.0 million 

Linear low-density polyethylene (LLDPE) 6.8 million 

High-density polyethylene (HDPE) 9.1 million 

Polypropylene (PP) 9.7 million 

Acrylonitrile butadiene styrene (ABS) 0.6 million 

Other Styrenics 0.9 million 

Polystyrene (PS) 3.0 million 

Nylon 0.7 million 

Polyvinyl chloride (PVC) 7.3 million 

Thermoplastic Polyester (includes PET) 4.4 million 

Total Thermoplastics 46 million 

Source: 

ACC Plastics Industry Producers Statistics Group, as compiled by Veris Consulting, 

LLC 

 1

 Although we report plastics from the combustion database as tonnages, the database includes material 

quantities expressed in terms of heating values (Btu). To express this information as a tonnage, we assumed that 

plastic has a heating value of 13,625 Btu per pound, which is the midpoint of the 8,250 to 19,000 Btu/lb range for 

plastics reported by the Energy Information Administration (EIA 2008). Also, for the purposes of identifying 

materials as plastics in the combustion database, we assumed that the following materials are plastics: (1) ground 

toilet seats, (2) packaging trimmings, and (3) plastics. 

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Scrap Plastics 

(3) Trends in Generation: 

• Plastic generation has remained constant over the last several years. Measured by 

weight, production of plastic grew 2.6 percent from 2003 to 2007, as shown in 

Exhibit 2 (ACC 2008e). This is likely a reasonable indicator of trends in 

production of scrap plastic.

Exhibit 2: Summary of Plastic Markets from 2003 to 2007 

Tons of Plastic Used 

Sector 2003 2004 2005 2006 2007 

Transportation 2.4 million 2.4 million 2.4 million 2.3 million 1.7 million

Packaging 12 million 13 million 13 million 13 million 13 million

Building & Construction 7.2 million 7.8 million 7.7 million 7.7 million 7.1 million

Electrical/Electronic 1.4 million 1.5 million 1.5 million 1.3 million 1.0 million

Furniture & Furnishings 1.7 million 1.7 million 1.7 million 1.7 million 1.5 million

Consumer & Institutional 8.8 million 9.4 million 8.7 million 8.9 million 8.6 million

Industrial/Machinery 0.5 million 0.5 million 0.5 million 0.5 million 0.5 million

Adhesives/Inks/Coatings 0.6 million 0.6 million 0.6 million 0.6 million 0.5 million

All Other 1.0 million 1.1 million 1.1 million 1.0 million 0.8 million

Exports 4.5 million 5.0 million 4.9 million 5.0 million 6.2 million

Total Selected Plastics: 40 million 43 million 42 million 42 million 41 million

Source: 

ACC Plastics Industry Producers Statistics Group, as compiled by Veris Consulting, LLC 

Note:

 Selected plastics include LDPE, LLDPE, HDPE, PP, Nylon, PVC, Engineering Resins, PS, ABS, Styrene-Acrylonitrile 

(SAN), Other Styrene-Based Polymers, and Styrene Butadiene Latexes. Data from 2007 do not include ABS, SAN, Other 

Styrene-Based Polymers, and Engineering Resins. 

• An index from the same source reports sales and intra-company use of major 

plastic resins in the fourth quarter of 2007 were slightly lower than the first 

quarter of 2002, with a peak of 10 percent higher than 2002 in the third quarter of 

2004 and a trough of 8 percent lower in the second quarter of 2003 (ACC 2008f). 

See Exhibit 3 below.

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Scrap Plastics 

Exhibit 3: Trend of Sales for Major Plastic Resins 

Source: ACC Plastics Industry Producers Statistics Group, as compiled by Veris Consulting, LLC 

3. Uses of Scrap Plastics 

(1) Fuel Uses: Combustion of post-industrial scrap plastic for energy in the United States 

does not appear to represent a high volume alternative fuel option. Data suggest that 

the same characteristics that increase the value of plastic scrap as an alternative fuel 

(e.g., high energy value) also increase its value as an input to recycled products, 

because it avoids the expense and raw material costs associated with virgin plastic. 

Anecdotally, however, several examples of cement kilns, boilers, and other 

incinerators using plastic as a fuel source exist:

• A cement kiln in Westport, New Zealand, experimented with sourcing scrap from 

plastic manufacturers in 2006 (Plastics New Zealand 2006, p.1). 

• A consultant with expertise in environmental regulatory compliance reports that 

plastic scrap from pharmaceutical packaging and diaper manufacturing scrap have 

been or are considered usable in cement kilns (Gossman 2007). 

• A Holcim representative reports that the company uses off-spec plastic products 

in its cement kilns (Guerra 2008). The company also in some cases obtains 

plastics from recyclers who handle MSW and commercial waste. 

• Dynegy Midwest Generation was reported to burn more than 500 tons of 

polyurethane scrap and other materials per day in engineered fuels to generate 

electricity. According to Dynegy's estimates, for each ton of coal displaced by 

polyurethane scrap, there is a reduction of more than eight pounds of SO2 

emissions. (Center for the Polyurethanes Industry 2007.) 

• KeLa Energy, LLC, has a patent pending binding process to create synthetic coalbased engineered fuels using readily available waste plastics and plastic 

composites, including post consumer carpet, to bind waste coal fines. Biomass 

may also be included in the binder system. The KeLa synfuel produces lower 

SO2 and NOx emissions than does coal. The engineered fuel has been tested in 

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Scrap Plastics 

industrial boilers and work is ongoing to allow its use in utility boilers. (KeLa 

Energy press release, 2007). 

Because it is a refined hydrocarbon material, plastic scrap is a high-value alternative 

energy source. However, plastics from some sources may be contaminated in ways 

that limit their value as fuel. For example, mixed plastics may include PVC, and the 

presence of significant levels of heavy metals (e.g., e-waste) make certain types of 

plastic scrap unfavorable for use as a fuel. 

(2) Non-Fuel Scrap Plastic Uses: The vast majority of scrap plastic is mixed with virgin 

plastic of the same type and reused in the same or a similar manufacturing process. 

This process is called “regrinding.” Numerous other products are made from 

“downcycled plastic.” The American Chemistry Council reports (ACC 2008d):

• Recycled PET can be used in new food and beverage bottles (i.e., “closed loop” 

recycling) and “downcycled” into deli trays, carpets, clothing, and automobile 

parts. 

• Recycled HDPE can become bottles for laundry products and motor oil, recycling 

bins, agricultural pipe, bags, garden edging, decking and plastic lumber. 

• Recycled vinyl can become playground equipment, flooring tiles, film, and air 

bubble cushioning. 

• Recycled LDPE can be used to manufacture bags, compost bins, and plastic 

lumber. 

• Recycled PP can be used in automobile parts including battery casings, textiles, 

industrial fibers, and films used for bulk packaging. 

• Recycled PS can be used in products including office accessories, garden nursery 

supplies, and protective package cushioning. 

(3) Quantities of Scrap Plastics Landfilled: Due to the efficiency with which postindustrial plastic scrap can be recycled and the robust market for plastic scrap, it does 

not appear that significant volumes of post-industrial plastic scrap end up in landfills. 

An exception may be off-spec products with multiple materials, although data are not 

readily available to quantify this.

(4) Quantities of Scrap Plastics Stockpiled/stored: Data are not readily available on 

the stockpiling or storage of plastic scrap, but because there is no restriction on 

disposal, it is likely that most discarded plastic is disposed of in municipal or other 

non-hazardous landfills. It is possible that private stockpiles of plastic exist, but 

given the high market prices for scrap plastics at this time it is not likely to be a 

widespread practice.

4. Management and Combustion Processes for Scrap Plastics 

(1) Types of Units Using Plastic Scrap as a Fuel: As explained above, combustion of 

post-industrial scrap plastic appears to be common in the cement industry. We are 

unable to find evidence of wide-spread combustion of post-industrial scrap plastic in 

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Scrap Plastics 

the United States by other industrial furnaces or boilers, beyond the examples noted 

above. 

(2) Supply/Processing Chain for Plastic Scrap: As described earlier, a significant 

portion of plastic scrap is reworked into the production process (i.e., recycled 

internally). In this case, no transportation is necessary. Off-spec materials used as 

fuel appear to be transferred directly from the producer to the combustion unit or fuel 

blender, where they are typically ground or shredded prior to combustion. For postconsumer (MSW) plastic, the process is somewhat different. Material is collected 

and sorted by municipal recycling facilities (MRFs) or private sector recycling 

operations into different common types of plastic such as PET and HDPE, and in 

many cases some decontamination also takes place prior to baling the product to sell 

as scrap. 

(3) Processing Scrap Plastic for Fuel Applications: 

 In a mass burn furnace, plastic scrap could be combusted with no further processing. 

In an refuse-derived fuel (RDF) facility and in most cement kilns and boilers, scrap is 

shredded prior to combustion and mixed with other fuel sources to provide a 

consistent fuel stream. Because industrial scrap plastic is typically uncontaminated 

and of a single type, it is unlikely that facilities with industrial boilers or kilns would 

need to clean the plastic prior to combustion. 

(4) Changes to Increase Use in Combustion: Post-industrial plastic scrap is already 

well-suited to combustion due to the high energy content and uncontaminated nature 

of most of this material. From the limited data available, it appears that use of postindustrial plastic scrap as fuel is not more widespread due to competing uses as an 

input into new plastic product manufacturing. 

(5) State status of Scrap Plastic use as Fuel: 

 At this stage we have not identified any states that have approved use of scrap plastics 

as fuel, but we have not performed an exhaustive investigation of state activities and 

regulations. 

5. Scrap Plastic Composition and Impacts 

(1) Composition of Scrap Plastic

 Scrap plastic has a high energy content ranging from 8,250 to 19,000 Btu per pound 

(EIA 2008). This can compare favorably with coal at 10,300 Btu/pound (EPA 2008a). 

Non-halogenated plastics are composed primarily of hydrocarbons with the addition 

of a wide variety of possible additives (ACC 2008b). PVC contains a substantial 

amount of chlorine. 

 

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Scrap Plastics 

Exhibit 4: Heating Value for Common Plastics 

Plastic Type Btu/Lb.

PP 19,000

PS 17,800

LDPE/LLDPE 12,050

PET 10,250

Other 10,250

HDPE 9,500

PVC 8,250

Source:

EIA 2008 

(2) Impact Information

• Greenhouse Gas Emissions: The greenhouse gas emissions from combustion of 

plastics vary by type of plastic. Combustion of HDPE produces the highest GHG 

emissions with 0.149 MTCO2E per MMBtu, while PP produces the lowest at 

0.072 MTCO2E per MMBtu. Generally, plastics appear to have higher 

greenhouse gas emissions than primary fuel sources. The emission factors 

associated with several common types of plastic are listed in Exhibit 5. By 

comparison, based on emissions and energy data compiled by EPA, the GHG 

emissions rates for coal, natural gas, distillate oil, and residual oil are 

approximately 0.094 MTCO2E per MMBtu, 0.053 MTCO2E per MMBtu, 0.073 

MTCO2E per MMBtu, and 0.079 respectively (EPA 2008b, Table A-10). 

• Criteria Pollutants and Hazardous Air Pollutants: Although several studies 

have been conducted on the criteria pollutant and hazardous air pollutant (HAP) 

emissions associated with combustion of plastics, most of these studies examine 

fuels that are a combination of plastics and other materials, especially MSW. 

Therefore, these studies do not isolate the criteria pollutant or HAP emissions 

associated with scrap plastics alone. Nonetheless, uncontaminated scrap plastics 

tend to be purified petrochemicals and potentially emit lower levels of pollutants 

than combustion of other fossil fuels. 

• Additional Avoided Impacts: In addition to other air emissions associated directly 

with combustion, use of scrap plastics as a replacement for traditional primary 

fuels may eliminate the environmental impacts associated with extraction and 

processing of the traditional fuels. Note that this assumes that the scrap plastic 

used as fuel is not economically recyclable. Exhibit 6 lists the quantities of 

cradle-to-gate emissions for these fuels based on typical processes in the United 

States in the late 1990s. 

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Scrap Plastics 

Exhibit 6: Emissions from Extraction and Processing of Traditional Fuels 

Coal 

Distillate 

Fuel Oil 

Residual 

Pollutant Fuel Oil Wood Natural Gas 

-------------------- Lb./MMBtu -----------------

Criteria Pollutants 

PM2.5 - - - - -

PM10 - - - - -

PM, unspecified 0.246 0.012 0.012 6.67x10-4 0.004

NOx 0.022 0.061 0.062 0.08 0.117

VOCs 0.008 0.361 0.365 - 0.515

SOx 0.022 0.186 0.187 0.003 1.913

CO 0.017 0.046 0.046 0.022 0.223

Pb 2.60x10-7 1.01x10-6 1.00x10-6 - 2.72x10-7

Hg 8.17x10-8 1.87x10-7 1.87x10-7 - 7.18x10-8

Greenhouse Gases

CO2 3.9 19 19.1 - 15.3

CH4 0.451 0.029 0.029 - 0.369

N2O 1.63x10-5 2.01x10-5 2.07x10-5 - 1.17x10-5

MTCO2E/MMBtu 0.006 0.009 0.009 - 0.01

Source:

Franklin Associates 1998 

Note:

“-” signifies data not available; may equal zero. 

The emission information presented in this table is derived from Life Cycle Inventory (LCI) data, as 

compiled by Franklin Associates. LCI data identifies and quantifies resource inputs, energy requirements, 

and releases to the air, water, and land for each step in the manufacture of a product or process, from the 

extraction of the raw materials to ultimate disposal. The LCI can be used to identify those system components 

or life cycle steps that are the main contributors to environmental burdens such as energy use, solid waste, 

and atmospheric and waterborne emissions. Uncertainty in an LCI is due to the cumulative effects of input 

uncertainties and data variability. 

There are several life cycle inventory databases available in the U.S. and Europe. For this paper, we applied 

the most readily available LCI database that was most consistent with the materials and uses examined. These 

LCI data rely on system boundaries as defined by Franklin Associates, as described in the documentation for 

this database, available at: http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf. 

• Cost Impacts: A Holcim Group Ltd. representative reports that in most or all 

cases, Holcim is paid by manufacturers to take their plastic scrap. This 

arrangement often represents a cost savings to generators due to avoided disposal, 

although in some cases manufacturers are willing to pay a premium over other 

options to see their plastic scrap used for productive purposes (Guerra 2008).

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Scrap Plastics 

Finally, note that, while scrap plastic represents a high-quality fuel source, at this time postindustrial scrap plastic appears to be more valuable as recycled products. As energy prices rise, 

making plastic a more attractive fuel source, the prices of virgin plastic also rise, resulting in 

increased emphasis on recycling. However, for plastics that are difficult or impossible to recycle 

economically, combustion of scrap plastic, particularly by cement kilns, is increasingly attractive 

both as a cost savings opportunity for companies, and also as an opportunity to ensure that they 

are optimizing their materials management strategies to recover the value of their materials.

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Scrap Plastics 

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