Gasifying Hazardous Wastes: EPA s Regulatory Strategy Rick Brandes, Chief Waste Minimization Branch U.S. EPA Office of Solid Waste

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1 Gasifying Hazardous Wastes: EPA s Regulatory Strategy Rick Brandes, Chief Waste Minimization Branch U.S. EPA Office of Solid Waste 4/2/2007 US EPA Presentation for Gasification Workshop 1

2 A Significant Opportunity Turn an expensive hazardous waste problem into a solution for energy needs and a source of valuable products using gasification 4/2/2007 US EPA Presentation for Gasification Workshop 2

3 What is Gasification? A technology that can convert carbonaceous material such as coal, petroleum coke, and other materials into a synthesis gas using high temperature and pressure. Synthesis gas can be used as a fuel source or as a building block for other chemical processes 4/2/2007 US EPA Presentation for Gasification Workshop 3

4 Why Gasification of Hazardous Materials? The technology has the potential ability to convert hazardous materials into energy and products in an environmentally sound way. It can reduce complex wastestreams into component parts forming products, capture halogens as products, generates a frit that binds up pollutants, prevents pollution due to higher efficiency 4/2/2007 US EPA Presentation for Gasification Workshop 4

5 What Regulatory Hurdles Would Need to be Overcome? Technologies that utilize or treat hazardous wastes are usually subject to RCRA and its requirements: hazardous materials sent to the gasifier would need to be manifested storing hazardous materials at the site would require a RCRA permit 4/2/2007 US EPA Presentation for Gasification Workshop 5

6 Regulatory Hurdles (continued) hazardous waste code carry-through causes residuals to be hazardous wastes syngas would have to meet fuel specs to remove waste-derived label 4/2/2007 US EPA Presentation for Gasification Workshop 6

7 A Solution If we can consider hazardous materials going to gasifiers as feedstocks to an industrial process, regulatory jurisdiction would not apply and the gasifier would operate as a process unit. 4/2/2007 US EPA Presentation for Gasification Workshop 7

8 Why Would Gasifiers and Generators Want to Gasify Hazardous Waste? It makes good environmental sense and could make good business sense: taking materials out of hazardous waste management system as you create products and energy eliminates wastestreams gasifiers may have a lesser environmental footprint than other systems for all media 4/2/2007 US EPA Presentation for Gasification Workshop 8

9 Why Would Gasifiers and Generators Want to Gasify Hazardous Waste? potential additional revenue source - charging a fee to take hazardous materials replaces some of the regular feed that would otherwise have to be paid for clean energy systems which may qualify for tax incentives 4/2/2007 US EPA Presentation for Gasification Workshop 9

10 What Direction is EPA Taking that Relates to Gasification? The Office of Solid Waste and Emergency Response plans to announce a Waste Reduction and Energy Recovery Initiative. The primary objective: increase recycling and energy recovery by providing a new kind of flexibility for promoting innovative ways to recycle wastes while reducing the nation s reliance on fossil fuels 4/2/2007 US EPA Presentation for Gasification Workshop 10

11 Universe of Secondary Materials Being Combusted According to 1997 EPA data, total nonwastewater hazardous wastes managed in United States was 35.1 million tons. Total hazardous waste combusted in 1997 was 3.3 million tons (nearly 10% of total above). 4/2/2007 US EPA Presentation for Gasification Workshop 11

12 Petroleum Refineries Potentially the proposal would directly affect the 150 petroleum refineries in the U.S. EPA data shows these facilities generating between 7 and 10 million tons of hazardous waste, some of which could be gasified. 4/2/2007 US EPA Presentation for Gasification Workshop 12

13 Summary of EPA s Gasification Proposal A conditional exclusion from the definition of solid waste. It will, if promulgated, say.. hazardous oil bearing secondary materials generated at petroleum refineries (SIC 2911) and inserted into gasifiers to produce a syngas used as an ingredient in chemical manufacturing OR AS A FUEL.. are not solid wastes. 4/2/2007 US EPA Presentation for Gasification Workshop 13

14 Conditions to Meet Proposed Exclusion: Gasifier meets definition of gasification system Synthesis gas meets fuel specification Limits on metals for materials placed onto the land Materials Management 4/2/2007 US EPA Presentation for Gasification Workshop 14

15 Definition of Gasification System An enclosed thermal device and associated gas cleaning system that does not meet the definition of an incinerator or industrial furnace (found at ) and that: 1) limits oxygen... To prevent full oxidation... 2) utilizes gas cleanup systems... 3) slags inorganic feed materials above 2000 degrees F, 4) produces a synthesis gas, and 5) is equipped with monitoring devices to ensure quality of synthesis gas. 4/2/2007 US EPA Presentation for Gasification Workshop 15

16 Fuel Specification Manufactured synthesis gas must meet the specifications found at 40 CFR (b) Designed to ensure that the synthesis gas produced from excluded material is a legitimate fuel product. 4/2/2007 US EPA Presentation for Gasification Workshop 16

17 Metal Limits for Materials Placed on the Land Non-wastewater Universal Treatment Standards found at 40 CFR All products, residues, by-products generated by the gasification of excluded materials placed on the land cannot exceed UTS for six metals 4/2/2007 US EPA Presentation for Gasification Workshop 17

18 Metals Limits (continued) Antimony Arsenic Chromium Lead Nickel Vanadium 1.15 mg/l TCLP 5.0 mg/l TCLP 0.60 mg/l TCLP 0.75 mg/l TCLP 11.0 mg/l TCLP 1.6 mg/l TCLP 4/2/2007 US EPA Presentation for Gasification Workshop 18

19 Excluded Material Management Prior to Processing Standard condition for recycling and re-use exemptions and exclusions: no speculative accumulation and no land placement prior to insertion into the gasification system 4/2/2007 US EPA Presentation for Gasification Workshop 19

20 Rationale for Proposing Exclusion of Oil Bearing Secondary Materials Gasification of these materials involves the recovery of organic components from crude oil to produce a product -- hence it is a fuel production process in petroleum refining operations. Gasification systems resemble fuel manufacturing devices more than they resemble RCRA treatment units. 4/2/2007 US EPA Presentation for Gasification Workshop 20

21 Rationale for Proposing Exclusion of Oil Bearing Secondary Materials (cont d) If they are production devices, the feeds going into the units are feedstocks, not wastes. Note that other attributes such as efficiency make us consider gasification part of the solution to waste management problems. 4/2/2007 US EPA Presentation for Gasification Workshop 21

22 Option for a Broader Conditional Exclusion Proposal also requests comment on whether the exclusion should be broadened to include other hazardous materials generated by other industries if those materials are sent to gasifiers. 4/2/2007 US EPA Presentation for Gasification Workshop 22

23 Three of the Conditions Remain the Same Definition of a gasification system Synthesis gas meets fuel specifications Materials management prior to processing 4/2/2007 US EPA Presentation for Gasification Workshop 23

24 Conditions Under Consideration for Expansion of Exclusion One Condition Expanded: metals added to the list: barium, beryllium, cadmium, cyanides (total and amenable), mercury, selenium, silver, and thallium Two conditions added: content of the materials and prohibitions on mercurycontaining materials 4/2/2007 US EPA Presentation for Gasification Workshop 24

25 Condition 5 Requires each hazardous secondary material processed to contain greater than 20% Total Organic Carbon Ensures that every feed material contributes to the manufacture of syngas 20% TOC threshold approximates the lowest value material know to be effectively gasified for synthesis fuel production 4/2/2007 US EPA Presentation for Gasification Workshop 25

26 Condition 6 Prohibition on Mercury-containing Materials Excludes any hazardous wastestream which exhibits the characteristic of Hg and any waste for which Hg was a basis for listing (D009, K071, K106, F039, U151, P065, P092) Solicits comment on expanding prohibition to include other highly volatile metals 4/2/2007 US EPA Presentation for Gasification Workshop 26

Waste Minimization Branch U.S. EPA Office of Solid Waste

RCRA Gasification Initiative Knoxville, Tennessee April 12, 2005 Rick Brandes,, Chief Waste Minimization Branch U.S. EPA Office of Solid Waste 4/18/2005 1 An Opportunity Turn an expensive waste problem