Materials Characterization Paper In Support of the Proposed Rulemaking – Identification of Nonhazardous Seco ndary Materials That Are Solid Waste Scrap Plastics

March 18, 2010

========================= ==================== ===================== 1. Definition of Scrap Plastics

Scrap plastics under considerati on here comprise three categorie s of material: scrap material from the manufacturing of plastic items, off-specification (off-sp ec) manufactured plastic goods, and packaging materials used in shipments to indus trial users - typically pl astic film, pallets, and “peanuts.”

2. Annual Quantities of Scrap Pl astics Generated and Used

(1) Sectors that generate scrap plastics: Industrial scrap plastics are generated from the manufactur ing of plastic products and packaging, and from off-spec manufactured material.

• Plastic manufacturers (NAICS 325211) ar e responsible for generating various plastic resins that are then combined and molded into products. This sector is responsible for plastic production; generato rs reuse the vast majority of their manufacturing byproducts. It is efficient to rework this material back into industrial processes (OECD 2006 p.88). The ef ficiency stems from the fact that process scrap is typically made up of single-type plasti c. 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 ar e not readily available, but the largest market for the use of virgin plastic re sins 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 substan tial 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 Indust ry 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 pr oduction 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 measur ed 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 vol ume of plastic scrap generated would beScrap 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 a nd 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 recycl ed due to the efficiency with which manufacturers can reuse singl e polymer uncontaminated scrap in their production processes (OECD 2006 p.88). A representative of Holcim Group Support Ltd. reports that some scrap plastic – typi cally off-spec products – is obtained through direct agreements between specific producer s and cement kilns for fuel, but sources and quantities of plastics used are cons idered 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 survey ed for these rules annually combust 39,000 tons of materi al characterized as plastics. 1

Exhibit 1: Overview of Plastic Pr oduction 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 info rmation 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 assu med that the following materials are plastics: (1) ground toilet seats, (2) packaging trimmings, and (3) plastics.

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(3) Trends in Generation:

• Plastic generation has remained constant ove r 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 indicato r 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 Gr oup, as compiled by Veris Consulting, LLC
Note: Selected plastics include LDPE, LLDPE, HDPE, PP, Nylon, PVC, Engineering Re sins, 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-comp any use of major plastic resins in the fourth quarter of 2007 were slightly lo wer 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 th e second quarter of 2003 (ACC 2008f).
See Exhibit 3 below.

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Exhibit 3: Trend of Sale s for Major Plastic Resins

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

3. Uses of Scrap Plastics

(1) Fuel Uses: Combustion of post-industrial scrap pl astic for energy in the United States does not appear to represent a high volume a lternative 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 va lue as an input to recycled products, because it avoids the expense and raw material costs associ ated 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 (P lastics New Zealand 2006, p.1).

• A consultant with expertise in environm ental 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 th e company uses off-spec plastic products in its cement kilns (Guerra 2008). The company also in some cases obtains plastics from recyclers who ha ndle MSW and commercial waste.

• Dynegy Midwest Generation was reporte d to burn more than 500 tons of polyurethane scrap and other materials per day in engineered fuels to generate electricity. According to Dynegy's estimat es, for each ton of coal displaced by polyurethane scrap, there is a reducti on of more than eight pounds of SO2 emissions. (Center for the Polyurethanes Industry 2007.)

• KeLa Energy, LLC, has a patent pending bindi ng 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
SO 2 and NOx emissions than does coal. The engineered fuel has been tested in

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industrial boilers and work is ongoing to a llow its use in utili ty 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 so me 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-wast e) 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, carpet s, 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 e quipment, flooring tiles, film, and air bubble cushioning.

• Recycled LDPE can be used to manuf acture 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 in cluding 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 ma rket for plastic scrap, it does not appear that significant volumes of post-i ndustrial 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 plas tic 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 plas tics 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 com bustion of post-industria l scrap plastic in

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the United States by other industrial furn aces or boilers, beyond the examples noted
above.

(2) Supply/Processing Chai n for Plastic Scrap : As described earlier, a significant portion of plastic scrap is reworked in to the production pro cess (i.e., recycled internally). In this case, no transportati on is necessary. Off-spec materials used as fuel appear to be transferre d directly from the producer to the combustion unit or fuel blender, where they are t ypically ground or shredded prio r to combustion. For postconsumer (MSW) plastic, the process is so mewhat 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 a nd in most cement kilns and boilers, scrap is shredded prior to combustion and mixed w ith other fuel sources to provide a
consistent fuel stream. Because industrial scrap plastic is typically uncontaminated and of a single type, it is un likely that facilities with i ndustrial boilers or kilns would need to clean the plas tic prior to combustion.

(4) Changes to Increase Use in Combustion: Post-industrial plasti c scrap is already well-suited to combustion due to the high en ergy 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 exha ustive investigation of state activities and regulations.

5. Scrap Plastic Composition and Impacts

(1) Composition of Scrap Plastic Scrap plastic has a high energy cont ent ranging from 8,250 to 19,000 Btu per pound (EIA 2008). This can compare favorably wi th coal at 10,300 Btu/pound (EPA 2008a). Non-halogenated plastics are composed pr imarily of hydrocarbons with the addition of a wide variety of possible additive s (ACC 2008b). PVC contains a substantial
amount of chlorine.

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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, pl astics appear to have higher greenhouse gas emissions than primary fuel sources. The emission factors
associated with several co mmon 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 respect ively (EPA 2008b, Table A-10).

• Criteria Pollutants and Hazardous Air Pollutants: Although several studies have been conducted on the criteria po llutant 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. N onetheless, uncontaminated scrap plastics tend to be purified petrochemicals and pot entially 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 im pacts associated with extraction and processing of the traditional fuels. Note that this assumes that the scrap plastic used as fuel is not economically recycl able. Exhibit 6 lists the quantities of cradle-to-gate emissions for these fuels based on typical pro cesses in the United
States in the late 1990s.

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Exhibit 6: Emissions from Extraction and Processing of Traditional Fuels

Coal Distillate
Fuel Oil Residual
Fuel Oil Wood Natural Gas Pollutant
-------------------- 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

CO 2 3.9 19 19.1
- 15.3

CH 4 0.451 0.029 0.029
- 0.369

N 2 O 1.63x10 -5 2.01x10 -5 2.07x10 -5

- 1.17x10 -5

MTCO 2 E/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 identifie s 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. Th e LCI can be used to identify those system components or life cycle steps that are the main contributors to en vironmental burdens such as energy use, solid waste, and atmospheric and waterborne emissi ons. 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 pr emium over other options to see their plas tic scrap used for producti ve purposes (Guerra 2008).

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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 pr ices of virgin plastic also rise, resulting in increased emphasis on recycling. Ho wever, for plastics that are di fficult or impossible to recycle economically, combustion of scrap plastic, particul arly 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 strate gies to recover the value of their materials.

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