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P2 Awards, 1996 - Conrad Industries

William Conrad, President
Phillip Bridges, Vice President
Conrad Industries, Inc.
121 Melhart Road
Chehalis,Washington 98532

Re: Recognition of Achievement in Pollution Prevention--PMN 95-861

Dear Mr. Conrad and Mr. Bridges:

I am very pleased to inform you that EPA's Office of Pollution Prevention and Toxics (OPPT) is hereby recognizing Conrad Industries, Inc. for an important achievement in pollution prevention (P2). This achievement involves the new chemical substance and the innovative technology described in premanufacture notice (PMN) 95-861 submitted to EPA pursuant to Section 5 of the Toxic Substances Control Act (TSCA). This formal recognition of the P2 benefits of your PMN submission is given in anticipation of the imminent submission of a notice of commencement of commercial manufacture (per 40 CFR 720.102), whereupon manufacture commences and these benefits begin to accrue.

The process for manufacturing your new chemical represents a significant innovation in the chemistry for advanced plastics recycling, chemically converting post-consumer plastics into fuel-grade petroleum feedstocks. Conrad Industries' new technology has the potential to advance plastics recycling to include many plastics not currently recycled. Your process provides advantages over conventional plastics recycling in that the sorting of different plastics in the waste stream is not necessary and the process yields a consistent quality petroleum end product.

As part of the New Chemicals Program's P2 Recognition Program, I congratulate you for this technological innovation and for your environmental stewardship. EPA considers your new chemical and, more significantly, the technology associated with it, worthy of recognition because advanced plastics recycling is intended to work alongside the traditional curbside plastics recycling by addressing mixed post-consumer plastics, greatly expanding the amount of waste plastics that can be recycled.

You generically described the substance produced from your thermal depolymerization process (i.e., heating in the absence of oxygen to break down plastic polymer) as a waste plastics pyrolysis oil. While EPA continues to have significant concerns for the potential formation of dioxins/furans in stack emissions during the pyrolysis process, the manufacture of Conrad's substance (i.e., pyrolysis occurring in the presence of lime), as negotiated with EPA and modified by you during the PMN review, greatly reduces this potential.

OPPT has instituted the P2 Recognition Program as a means to encourage innovation and further pollution prevention. In addition to formal notice by letter, EPA is considering publicly listing P2 Recognition recipients on the Internet and perhaps in other media as well. The Agency may also publish articles describing the pollution prevention benefits of specific chemicals which are the subject of a PMN. As always, confidential business information claims will limit our ability to communicate about these new chemicals and to announce, describe and promote these P2 innovations. The Agency welcomes your ideas and comments on how best to recognize and spread the word about your and other noteworthy P2 accomplishments. In this particular case, it would be helpful if you would drop the CBI claims concerning chemical identity and process information.

Please realize that New Chemicals Program reviewers often rely heavily on information manufacturers supply on the P2 page of the Premanufacture Notice to identify recognition candidates. EPA urges all submitters to provide sufficient detail in a notice so that the Agency can perform a thorough analysis of P2 claims. In essence, pollution prevention means reducing or eliminating a potential pollutant before it is created. Ideally, P2 should be accomplished through innovative chemical design or redesign. EPA advocates P2 because it makes sense -- for the environment and the economy. By not creating a pollutant, one avoids the hazards and costs associated with controlling exposures to and releases of that pollutant.

While prevention is the preferred approach to environmental protection, the Agency recognizes the benefits of other approaches as well. In fact, the Pollution Prevention Act of 1990 lists recycling as the second tier, following prevention, in its environmental management hierarchy. Your innovative new chemistry and technology have the potential to greatly expand the universe of what can be recycled, rather than discarded as waste, thereby promoting pollution prevention. (For more information on P2, see EPA's Pollution Prevention homepage: http://www.epa.gov, select "Search" then type "p2home.")

Since EPA has only limited information on your P2 Recognition chemical, I ask that you keep the Agency informed of this substance's commercial success over time, any toxicity data that becomes available, and the uses you make of this P2 recognition (e.g., in product literature or advertising). Please note that under Section 5 of the Federal Trade Commission Act any marketing claims based on this letter must be accurate and not misleading. (For additional information, see "Guides for the Use of Environmental Marketing Claims" issued by the Federal Trade Commission on July 28, 1992 at 57 FR 36363, codified at 16 CFR Part 260, and reissued in October 1996. Copies of the Guide are available by calling the FTC at (202) 326-2222 or on the Internet at http://www.ftc.gov under the heading "Consumer Protection Rules and Guides" and the subheading "Environmental Marketing Guides.")

When you have new information or if you have any questions regarding the P2 Recognition Program, please contact Roy Seidenstein (202-260-2252) or Kenneth Moss (202-260-3395). You can reach Mr. Seidenstein or Mr. Moss by fax at 202-260-0118; by mail at US EPA, Office of Pollution Prevention and Toxics, MC 7405, 401 M Street, SW, Washington, DC 20460; or via e-mail at seidenstein.roy@epamail.epa.gov or moss.kenneth@epamail.epa.gov.

Again, congratulations on your pollution prevention achievement. The Agency wishes you continued success with future innovations.

William H. Sanders III, Dr. P.H., P.E.
Director, Office of Pollution Prevention and Toxics

cc: Robert Oeck, Clean Air Products
     P.O. Box 1669
    14230 SE 98th Court
    Clackamas, Oregon 97015

    Carol Hetfield, EPA



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