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Urethane Recycling as a Component of a Responsible Waste Management Program

Presented by: Sean Easton Effective Environmental

Today’s Agenda

§  Overview of Waste Rules §  The Recycling Exemption §  Long-term Liability Considerations §  Existing Urethane Recycling Options §  Case History §  Summary

A General Waste Overview

§  Solid wastes that are discarded must be characterized to determine if they may be classified as HAZARDOUS wastes (listed or characteristic)

§  Materials that are recycled (used, reused or reclaimed) are exempted from the solid waste/hazardous waste determination

State Waste Rules May Vary

§  Some states have enacted additional requirements for the management of industrial wastes

§  Texas requires further characterization of industrial waste as either Class 1, 2 or 3 nonhazardous

E2 Recommendation

§  Whether intended for disposal or recycling, perform a formal hazardous waste characterization §  Generator knowledge and/or lab

analysis §  Document the characterization

§  Repeat the characterization any time the production process changes

Cradle to Grave Liability

§  The primary concern for waste generators is typically NOT the permitted landfills and incineration facilities

§  Recycling facilities have low barriers to entry, and little or no regulatory oversight

§  If a recycler is forced into a cleanup (Superfund), it’s clients likely become the Potentially Responsible Parties (PRPs)

Escaping (?) PRP Status

§  Presentation of documented waste characterization protocols should relieve the generator of cleanup responsibility

§  Due diligence of your recyclers should be as (if not more…) important as your selected waste disposal vendors

Advanced Recycling Options

§  Glycolysis produces polyols, a key polyurethane raw material, from process and post-consumer polyurethane scrap by reacting polyurethanes with diols at high temperatures

§  Hydrolysis, a reaction of polyurethane with water, can produce polyols and amine intermediates from polyurethane process and post-consumer scrap

Advanced Recycling Options

Pyrolysis uses a heated, oxygen-free environment to break down polyurethane and plastics into gas and oil Hydrogenation takes pyrolysis one step further to produce pure gases and oils through a combination of heat, pressure and hydrogen

Source: Center for the Polyurethanes Industry website – “Recycling & Waste Reduction”

Urethane Scrap Recycling

§  Some forms of urethane waste can be directly recycled into new products §  Shavings used as biomass

accumulators for use in fish tanks §  Scrap foam converted to polyurethane

carpet cushion and athletic mats §  Shredded scrap used as packaging and

stuffing for pillows, plush toys, etc.

Challenges to Urethane Recycling

§  Unless one of these direct recyclers is nearby, transportation costs can far exceed savings

§  The heat generated by grinding urethane can damage equipment without costly modifications

The “Green” Perspective

§  In general, recycling is NOT less expensive than landfill disposal

§  However, if the company has established “green goals,” a responsible recycler can help meet these initiatives

§  A full-service environmental firm can provide options that consider both the environmental AND economic costs

TD Williamson

§  TDW needed a solution for the handling of unused polyurethane pigs, cups and scrap

§  Recycling was preferred over landfill

§  Preferred a destructive method due to proprietary design

Solution Found

§  In order to minimize possibility of product theft, scrap shipped to plastic shredder who could process upon receipt

§  Company audited operations to insure the mixed plastic scrap was properly reused by downline processors

§  To further reduce liability, shipper’s indemnification extended to TDW

Summary

§  Evaluate your generating processes and constituents of all wastes

§  Document everything! §  Liability does not go away when the truck

leaves the yard §  There are advantages to partnering with

those who are not tied to one technology