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