Materials Characterization Paper In Support of the Proposed Rulemaking: Identification of Nonhazardous Seco ndary Materials That Are Solid Waste Purification Process Byproducts

March 18, 2010

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1. Definition of Purification Process Byproducts

Purification process byproducts are residual mate rials generated from production processes to isolate specific chemicals or compounds. Thes e secondary materials are made up largely of organic compounds that have a high molecular wei ght but are only somewhat volatile. Due to these characteristics, purification process byproducts are combustible but generally not flammable (Raiders et al. 2009). Purification process byproducts may be generated from several different processes, including di stillation, extraction, and evaporat ion (EIA 2000). This analysis addresses only purification pro cess byproducts that: 1) have poten tial fuel value or can be reused, and 2) are not consid ered hazardous under RCRA.

2. Annual Quantities of Purification Pr ocess Byproducts Generated and Used

(1) Sectors that generate purification process byproducts:

• Purification process byproducts are gene rated from a variety of purification processes used by a number of industries. Such processes are employed in the production of processed food, beverages, petroleum products, chemicals, and several other products. Industries that generate these materials include the following, listed by NAICS code:

o 311: Food Manufacturing

o 312: Food and Beverage Manufacturing

o 324: Petroleum Products Manufacturing

o 325: Chemical Manufacturing (Census Bureau 2009).

This list of industries is not necessarily exhaustive, given that purification process byproducts are generated by a wide range of processes used in the production of a variety of goods.

(2) Quantities and prices of purification process byproducts generated:

• Due to the wide variety of purification process byproducts generated, it is difficult to characterize the quantity or prices of purification process byproducts generated in the U.S. Overall, U.S. industrial f acilities generate approximately 7.6 billion tons of non-hazardous industrial solid wast e each year, which suggests that these facilities generate less than 7.6 billion tons of purification process byproducts on an annual basis (EPA 2008).Purification Process Byproducts

• As indicated above, the petroleum products sector is among the many industries that generate purification process byproducts. While comprehensive information on the generation and management of the industry’s purification process byproducts has not been identified, EPA conducted a survey in 1996 to evaluate the management of 15 petroleum refi ning residuals that the Agency was considering to list as hazardous wastes at the time. Exhibit 1 summarizes findings from the Agency’s survey.

Exhibit 1: Management of Select Petroleum Refinery Residues

Management Practice Percentage

Total Disposed 29.69%
Off-site Landfill 24.92%
On-site Landfill 3.88% Other Disposal Onsite/Roadbed mixing 0.14%
Other 0.74% Total Discharged 14.42% Onsite Wastewater Treatment Facility 1.46%
POTW 0.58% Surface Water (under NPDES) 10.99%
Offsite POTW 1.39% Total Recovered, Recycled, Reused, Regenerated 27.21% Metal Catalyst Reclamation/Regeneration 16.72% Recycle to Processes (e.g ., onsite recovery) 8.58% Miscellaneous Onsite Recycling 1.92%
Total Stored 0.16%
Total Stored in Piles 0.16%
Total Transferred 10.30% Transferred to Another Refinery 2.69%
Transferred for Direct Use as a Fuel or to Make Fuel 2.46% Transfer with Coke Product or Other Refinery Product 3.33%
Other 1.82%

Total Treated 18.21%
Neutralization 10.12%
Onsite Boiler 2.33%
Onsite Industrial Furnace 2.91%
Onsite Land Treatment 2.51%
Other 0.35%
Grand Total 100.00% (EPA 1996)

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(3) Trends in generation of purification process byproducts:

• Information on trends in the generation of purification pro cess byproducts is difficult to assemble given the range of products and management options. It is likely, however, that such trends will cl osely track production in those industries that generate purification process byproducts. These pr oduction trends are likely to vary by industry.

3. Uses of Purification Process Byproducts

(1) Combustion uses of purification process byproducts:

• Purification process byproducts with sufficient calorific value can potentially be used as fuels in boilers, furnaces, and kilns. However, the combustion uses are likely to vary depending on the source of the residue.

(2) Non-combustion uses of purif ication process byproducts:

• Comprehensive information on non-com bustion uses for purification processbyproducts has not been identified. The usability of these materials for noncombustion applications, however, is likel y to vary across different purification process byproducts and non-combustion use applications.

4. Management and Combustion Processes

(1) Types of units using purification process byproducts

• Information on the types of units usi ng purification process byproducts has not been identified, but industrial residues in general are used in a variety of combustion units, including liquid-fueled boilers and process heaters. (EPA 2004).

(2) Sourcing of purification process byproducts:

• Purification process byproducts originate at many different types of facilities (Raiders 2009). No information, however , has been identified on the collection and distribution of these materials.

(3) Processing of purificat ion process byproducts:

• Information on the processing of purifica tion process prior to their use has not been identified. It is likely, however, that processing requirements would vary across beneficial use applicati ons and purification byproducts.

(4) State regulatory status of purific ation process byproducts use:

• At this stage, we have not identified any states that have specifically granted a beneficial use designation for the use of purification process byproducts as fuel, but we have not performed an exhaustiv e investigation of state activities and regulations.

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5. Commodity Composition and Impacts

(1) Composition of purification process byproducts:

• The composition of purification proce ss byproducts can vary across specific byproducts. As indicated above, however, they are typically high in organics, which makes them a useful non-hazardous fuel source (Raiders et al. 2009). The concentrations of other c onstituents are difficult to characterize because they depend on the specific purification process from which the material was generated.

(2) Impacts of purification process byproduct use:

• Benefits associated with th e use of purification process byproducts as fuel include avoided risks associated with disposal, cost savings associated with avoided disposal and recovery of energy, a nd the avoided environmental impacts associated with production of energy from “virgin” non-renewable sources when purification process bypr oducts are used instead.

• The specific lifecycle impacts of purificati on process byproducts used as a fuel are not evaluated here because of uncertain ties in lifecycle scenario development. For example, it is difficult to identify th e fuel (Btu) value and emissions factors associated with a “typical” non-hazardous purification process byproduct that is suitable for fuel. In addition, purificati on process byproducts may substitute for a variety of fuels; the choice of fuel ofte n depends on location sp ecific-factors such as the location of the combustor in relati on to fuel supplies, and on the design of the specific combustion unit. Avoided upstream impacts depend heavily on the specific fuel being displaced in the lifecycle scenario.

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References

Raiders, Richard and Lew Buchanan , public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for Identification of Non-Hazardous Mate rials That Are Solid Waste, EPA docket EPA-HQRCRA-2008-0329, submitted on behalf of Arkema, Inc., February 2, 2009.

United States Census Bureau. 2008, “2007 NAICS Codes and Titles,” accessed April 16, 2009 at: http://www.census.gov/cgi-bin/sssd /naics/naicsrch?chart=2007

United States Energy Informa tion Administration (EIA). 2000, “Chemical Industry Analysis Brief: Technologies and Equipment,” accessed April 21, 2009 at: http://www.eia.doe.gov/emeu/mecs/iab/chemicals/page4.html

United States Environmental Protection Agency (EPA). 2008, “Guide for Industrial Waste Management.” Accessed on April 19, 2009 at: http://www.epa.gov/epawaste/nonhaz/industrial/guide/index.htm

United States Environmental Protection Agency (EPA). 2004, “Regulatory Im pact Analysis for the Industrial Boilers and Process Heaters NESHAP.

United States Environmental Protection Ag ency (EPA). 1996. “Study of Sel ected Petroleum Refining Residuals.” Accessed on April 21, 2009 at http://www.epa.gov/osw/hazard/wastetypes/wasteid/petroleum/study_p1.pdf.

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