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Proposed New Definition of Solid Waste Rule

EPA July 22, 2011, proposed a new Definition of Solid Waste Rule, that would exclude from the Definition of Solid Waste 18 spent solvents used as manufacturing and processing aids in four industrial sectors if they are remanufactured (re-processed) to commercial grade. This would reduce the use of virgin solvents, reducing energy and waste. If the remanufacturing is conducted onsite, the proposed Generator-Controlled Exclusion would be operative; if the remanufacturing were to be conducted by a third-party within one of the four sectors, the Remanufacturing Exclusion (listed for comment) would be operative.

Benefits

These regulatory exclusions for remanufacturing spent solvents to commercial grade have environmental and economic benefits. By allowing used solvents, under appropriate conditions, to have longer commercial life, the proposal would allow the market to slow the pace at which virgin solvents are created and destroyed. Since creation and destruction of solvents are environmentally and economically intensive events, and since remanufacturing (re-processing) solvents is less intensive environmentally and economically than either creation of virgin solvents or the destruction of solvents, net benefits are achievable.

EPA is requesting comment on the Remanufacturing Exclusion, and EPA's Green Engineering Program is especially interested in hearing from chemical manufacturers on the extent the proposed exclusions could be expected to provide economic and environmental benefits.

Resources

Mass-Balance Model. To help facilities in the four listed sectors (see "Background" below) assess the potential benefits of these exclusions, EPA has developed a mass-balance model tool to share for assessing how remanufacturing spent processing-aid solvents can benefit operations. The tool allows the user to put in the volume of spent solvent (any or all of the 18 listed solvents) to calculate reductions in energy use, reduced air, water and solid waste emissions and enumerated cost savings associated with switching from disposal to remanufacturing.

Qualified facilities may contact the Green Engineering program for assistance in using the EPA tool for assessing these potential benefits of remanufacturing scenarios.

EPA's Sector Notebooks. Another resource EPA has available for the four sectors covered by the Remanufacturing Exclusion are EPA's Sector Notebooks. Since the Remanufacturing Exclusion allows for third-party remanufacturing, sectors may find it helpful to learn about each others' material flows and energy uses for purposes of third-party remanufacturing. These notebooks provide that information, and are organized in an integrated fashion across processes, environmental media, and applicable regulations.

Pharmaceutical Sector Profile Notebook:
http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/pharma.pdf

Plastic & Resin Sector Profile Notebook:
http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/resfibsn.pdf

Basic Organic Chemical Manufacturing Sector Profile Notebook:
http://www.cluin.org/download/toolkit/organic.pdf

Paint & Coatings: No sector notebook, but all paints and coatings start with a film-forming agent, which is a resin.

Background

The proposed remanufacturing exclusion addresses four manufacturing sectors: pharmaceutical, paint and coating, plastic and resin, and basic organic chemicals. These all use the 18 listed solvents for the listed functions (as chemical manufacturing and processing aids) to manufacture specialty organic chemical products, such as paints, plastics or drugs.

Remanufacturing Qualifying Sectors with Links to Toxic Release Inventory DatabasesExit EPA Disclaimer

All Other Basic Organic Chemical Manufacturing
Rank by Waste: 1st (2,507,659,932 lbs)
2009 Rank by Release: 7th
Number of TRI submissions: 3230

Plastics Material and Resin Manufacturing
Rank by Waste: 3rd (1,182,555,225 lbs)
2009 Rank by Release: 15th
Number of TRI Submissions: 2472

Pharmaceutical Preparation Manufacturing
Rank by Waste: low (127,941,376 lbs)
2009 Rank by Release: 75th
Number of TRI Submissions: 376

Paint and Coating Manufacturing
Rank by Waste: low (88,569,586 lbs)
2009 Rank by Release: 61st
Number of TRI Submissions: 2187

Proposed Eligible Chemicals

EPA has identified eighteen chemicals that could be included in the re-manufacturing exclusion, in which 16 are reported in the Toxics Release Inventory. They are toluene, xylenes, ethylbenzene, 1,2,4-trimethylbenzene, chlorobenzene, n-hexane, cyclohexane, methyl tert-butyl ether, acetonitrile, chloroform, chloromethane, dichloromethane, methyl isobutyl ketone, nn-dimethylformamide, tetrahydrofuran, n-butyl alcohol, ethanol, and/or methanol. Read More.

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