March/April 1996
While most recycling residues are disposed of today, some processors have found value in this material. Here’s a look at what processors are doing with their residues, including how some are putting the material to beneficial use.
By Lynn R. Novelli
Lynn R. Novelli is a writer based in Russell, Ohio.
In a rose-colored world, all scrap materials would be 100-percent recyclable. Scrap recyclers would be able to process all imaginable scrap without generating any residues or wastes.
But, of course, this isn’t a perfect world.
Some scrap commodities, particularly automobiles and insulated wire, aren’t 100-percent recyclable. As a result, recyclers of these materials inevitably generate residues—namely, shredder residue (for the purposes of this article defined as shredder waste containing minimal or no nonferrous metals) and wire-chop tailings.
Though these residues contain potentially recyclable materials such as plastics and foam rubber, the costs of recycling them has, thus far, been largely prohibitive. Hence, most of these materials have been—and continue to be—disposed of.
This practice has, at times, been a hot potato among some regulators, legislators, and the public due to concerns that recycling residues could potentially leach toxic constituents when disposed of in landfills. This issue was especially hot in the early 1990s when the U.S. EPA changed the testing procedure required under RCRA to determine if a waste is hazardous due to toxicity, replacing the Extraction Procedure (EP) Toxicity test with the more aggressive Toxicity Characteristic Leaching Procedure (TCLP). The new test put shredder operators and wire choppers on the defensive, forcing them to prove that their residues are nonhazardous and making it more difficult, for a time, to dispose of the material.
Fortunately, many recyclers have since done just that, establishing the environmental safety of their residues, as well as their disposal methods. Further, more than half the states currently allow shredder residue and wire-chop tailings to be disposed of as municipal solid waste as long as it’s proven nonhazardous by state and/or federal TCLP testing.
But while the hot potato of the early 1990s has cooled, some processors feel that the current state of truce is only temporary. And, thus, many have set their sights on finding new solutions for their recycling residues.
The Tribulations of Tailings
Under the old EP Toxicity test, wire-chop tailings had little, if any, problem testing nonhazardous.
It’s been a different story under the TCLP, which reportedly causes more failures than the old test—particularly for copper wire tailings that include lead-containing PVC insulation.
To pass the TCLP—and enable the disposal of their tailings in nonhazardous landfills—many wire choppers treat their PVC tailings to stabilize the lead, usually by mixing the material with alkaline chemicals or phosphate solutions. Some larger wire choppers have even developed their own treatment processes, such as Reclaimers Inc. (Kendallville, Ind.), which has treated and landfilled 37,500 tons of tailings since 1990 using its proprietary system for rendering wire- chop residue nonhazardous— without a single rejection, according to Tom Feichter, president.
One downside to treatment is that the capital investment required can be high. But treating tailings and staying competitive in the market are not mutually exclusive, say choppers who have taken this step.
There are also regulatory considerations to treatment. Under federal rules, a permit or other regulatory approval is generally required for any activity considered treatment of hazardous waste. If the waste is processed through a totally enclosed in-line treatment system, however, then such approval is generally not necessary. In this case, though, the waste generator must show that the treatment system is part of the production process and not simply a means to treat hazardous waste.
Smaller choppers who are unwilling or unable to assume the expense of treating tailings often restrict their operations to bare wire or insulated aluminum wire and cable, which is commonly sheathed in polyethylene rather than PVC, thus eliminating the lead concerns and generally making disposal easier.
Virtually all wire choppers, however, generate some tailings that must be disposed of as nonhazardous solid waste, which can be easy or difficult depending on the state. Choppers in Arizona, Arkansas, Louisiana, New Mexico, Oklahoma, and Texas, for instance, report low tipping fees, paying as little as $20 a ton to landfill their nonhazardous residues.
Other choppers face greater disposal challenges and steeper landfilling costs. Lee Levant, president of Gulf Coast Metals Co. Inc. (Tampa), for example, notes that land disposal is problematic in Florida due to the state’s high water table, which is blamed for tipping fees that fall around $40 to $50 a ton. Then again, that state’s fees aren’t so bad compared with fees in the Northeast, which are said to average around $70 a ton.
Disposing of Shredder Residue
In contrast to wire choppers, shredder operators have found the TCLP to be more friendly in its test results on their residue. “The industry now has nearly five years of TCLP data to support the safety and stability profile of shredder residue in landfills,” says William Z. Baumgartner, president of W.Z. Baumgartner & Associates Inc. (Brentwood, Tenn.). “Every few years, some states decide to take a closer look at shredder residue. The data quickly settle any controversy because they demonstrate the benign nature of this material.”
In particular, the industry’s accumulated TCLP data show that, on average, shredder residue meets the definition of a nonhazardous solid waste and, in general, poses no leaching concerns regarding RCRA heavy metals, he notes.
Aside from RCRA’s hazardous waste requirements, shredder operators are also required under the Toxic Substances Control Act (TSCA) to dispose of their residue in a TSCA-approved landfill if the total concentration of PCBs in the residue exceeds 50 ppm. The problem of PCBs in shredder residue is diminishing, thanks to a 1979 ban on the use of PCBs in most manufactured products. Even so, ReMA is working with the EPA to change the PCB testing protocol under TSCA from a concentration-based standard to a leachability-based standard similar to the TCLP to better reflect the immobile nature of PCBs in shredder residue.
Part of the secret to ensuring shredder residue is free of leachable toxics apparently lies in implementing thorough source control procedures, in which inbound shred-dable scrap is kept free of potentially worrisome components such as batteries, capacitors, and wheel weights. “Disposal of recycling residue is not problematic if the operator is diligent on a daily basis with source control,” says Kelly Nash, environmental manager for the secondary metals processing division of Commercial Metals Co. (Dallas). “Dedicating funds to inspecting the feedstock saves a lot of money later on.” (For more on source control, see “How to Develop a Source Control Program” in the July/August 1994 issue.)
Don’t get the idea, however, that disposing of shredder residue is trouble-free. In 21 states, even if the material passes the TCLP, it is classified as a nonhazardous “special” waste subject to special management requirements. These handling procedures differ by state but may cover manifesting, storage, and transport specifications and disposal in designated special waste landfills.
One such state is Arizona, which designated shredder residue a special waste in the early 1990s, then deliberated for two years over which landfills could accept the material. During that period, shredders in the state had no choice but to stockpile their residue, with one—National Metals Co. (Phoenix)—accumulating more than 30,000 tons before the disposal question was settled. Thus, even today, National Metals is still disposing of several truckloads from the stockpile daily, along with newly generated shredder residue—to the total tune of 100-plus tons a day of business for the local landfill, says Barry Shapiro, the firm’s president. On top of the $22-a-ton tipping fee, National Metals and other shredders in Arizona pay an additional special waste tax of $2 a ton.
But Arizona’s 16 pages of shredder residue disposal rules pale compared with California’s disposal regulations, which require shredder operators to not only perform the TCLP on their residue to prove it’s nonhazardous and suitable for landfilling, but also to test it using an even more stringent procedure known as the Waste Extraction Test (WET), which uses citric acid as the leaching agent. The problem with this added requirement, according to Baumgartner, is that “no one can pass the citric acid test, so all shredder waste is considered hazardous in California based on extractable levels of cadmium, copper, lead, and zinc.”
Since its imposition in 1986, the test—which is currently under review—has had a dramatic effect on the California shredding industry. Several shredders have reportedly relocated their operations to other states, while others shut down when testing and treatment requirements squeezed already-tight operating margins out of existence.
Those who remain must either treat their waste at a cost of about $20 a ton—on top of a $35-a-ton tipping fee—or ship it out of state for disposal. Neither option is ideal. On the one hand, “treatment and disposal is our single highest operating expense,” says Mark Adams, manager of environmental affairs for Sims-LMC Recyclers (Richmond, Calif.). But, he adds, untreated material shipped out of state for disposal still must be handled as hazardous waste prior to and during shipping, negating any potential disposal savings.
Even so, some California shredder operators—such as George Adams, president of Adams Steel (Anaheim, Calif.)—view out-of-state disposal as preferable to dealing with the hassles of treating and disposing of the material in California. The company treated its shredder residue until 1993, when repeated landfill rejections prompted the company to ship its material to Arizona for disposal. Though this move is more expensive than its treatment program, “it’s a lot easier,” Adams states.
Still other shredder operators pursue both options, such as Proler International Corp. (Houston), which disposes of the residue generated by its California shredder both in state and out of state.
The Daily Cover Option
At the other end of the spectrum from states like Arizona and California are a handful of states—including Wisconsin, New York, Massachusetts, and Georgia—that have approved the use of shredder residue as a daily landfill cover in place of high-tech specialized foams or low-tech, but still relatively costly, soil. Although approval is on a site-by-site basis, meaning shredder operators must negotiate an agreement with specific landfills, landfill operators “are coming to realize that shredder residue makes excellent cover,” says Baumgartner. “It’s odorless, stable, and innocuous.” It’s important to note, however, that shredder residue can, in general, only be used as daily cover if it passes the TCLP.
To make the concept more attractive to landfills, some shredder operators process their residue into a landfill cover product by grinding it and mixing it with chemicals, dirt, or lime. In this way, the material becomes less like shredder residue and more like a mainstream daily cover.
The real beauty of this application is that it puts shredder residue to constructive use, rather than simply allowing it to be discarded, Baumgartner says, adding, “It’s the one way to recycle 100 percent of a vehicle.” Plus, it can not only enable shredder operators avoid disposal fees, but also, in some instances, sell their residues.
And what about using wire-chop tailings as daily cover? To date, that apparently hasn’t been proposed. “Wire choppers haven’t gotten together to take it to the next level, which would be site review by the EPA,” says one chopper. “There may be no physical differences between shredder residue and wire-chop tailings, but to my knowledge it has never been looked at.”
Beyond Disposal
While most recycling residues continue to be disposed of, some processors believe the focus needs to shift to recycling these materials. The real issues, they assert, are no longer testing and tipping fees but long-term environmental and fiscal responsibility. “It comes down to how much longer the industry will be able to dispose of residue in landfills,” says Dennis Caputo, Proler’s vice president of environmental and safety compliance. “Are we in the business of waste generation or recycling?”
Dick Zampiello, vice president of operations for Schilberg Integrated Metals Co. (Waterbury, Conn.), echoes this sentiment, adding that economics favor recovery over disposal. “Disposal costs are not recoverable, and landfill options are narrowing to a precious few,” he says. “Considering the seriously competitive nature of the wire chopping industry, we must address the 45 percent of the product that gets thrown away. Wire choppers may choose to play ostrich, but that’s like gambling with the family jewels.”
A few wire choppers have already blazed the recycling trail, creating systems that separate plastic tailings into separate polymer streams. This material is then used to make new plastic products such as truck mudflaps, planters, and seedling trays.
While some choppers are exploring such options, widespread acceptance of this approach will require a change in thinking on the part of wire choppers, Zampiello asserts. “Wire choppers have to realize that they are in the plastic business,” he says. “To survive, they will have to make a commitment to treating tailings to render the material nonhazardous, recovering the plastics, and making products out of the recycled plastic.”
Some shredder operators, meanwhile, have explored ways to recycle various components of their residue—the plastics, in particular—as well as options for using the material as a fuel source.
Proler, for instance, has developed a thermal process that transforms organic hazardous and special wastes such as shredder residue into usable gas. In its patented SynGas process, wastes are fed into a specially designed rotary reactor, which vaporizes the waste into its elemental components, then reforms the vapor through thermal conversion into a synthesis gas that can power boilers and generators, serve as a chemical feedstock for methanol, or assist in the direct reduction of oxides in steelmaking.
Through these and other efforts, wire choppers and shredder operators are seeking innovative ways to put their residues to beneficial use. It hasn’t been, and won’t be, an easy or quick task. In the near term, there will still be challenges regarding the testing, treatment, and disposal of recycling residues.
But perhaps someday, these challenges will dissipate. Perhaps, just perhaps, processors will bring about something more akin to a perfect world, in which all scrap is 100-percent recyclable and recycling residues are only memories.
If It Fails the TCLP, It’s Hazardous. Then What?
Recycling residues that fail the TCLP are considered hazardous waste and must be disposed of in compliance with strict—and costly—protocols.
For starters, facilities that generate hazardous waste must notify the regional EPA to obtain an identification number. The material must be transported via an authorized hazardous waste transporter with an EPA identification number to a permitted hazardous waste treatment or disposal facility. All containers must be packaged and labeled in accordance with U.S. Department of Transportation regulations and accompanied by a Uniform Hazardous Waste manifest from the EPA or a state hazardous waste manifest.
With fewer than a dozen hazardous waste landfills in operation around the country, some hazardous waste can require a trip of 500 miles or more, and tipping fees at these specialized landfills run about $330 a ton.
When all is said and done, disposal and cleanup of less than 100 tons of hazardous material can carry a price tag of $500,000 to $1 million. •
While most recycling residues are disposed of today, some processors have found value in this material. Here’s a look at what processors are doing with their residues, including how some are putting the material to beneficial use.