United States Environmental Protection Agency
Solid Waste and Emergency Response
Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009) (5305W)
            
EPA530-F-02-015
February 2002
http://www.epa.gov/osw 
             
Environmental Fact Sheet: EPA Proposing to Allow Waste as an Energy Source for
Synthesis Gas Production and Power Generation

EPA is Proposing to Conditionally Exclude, From RCRA's Definition of Solid Waste,
Hazardous Secondary Materials That are Processed in Gasification Systems to
Manufacture Synthesis Gas 
                        
Background                                                     

For the last 40 years, gasification technologies have been used commercially for the 
production of fuels and chemicals.  Modern gasification systems are designed to
convert carbon-containing materials into a synthesis gas product that can be used for
energy production or as a building block for other chemical manufacturing processes. 
Coal, petroleum coke, hazardous oil-bearing secondary materials from the refining
industry, municipal sewage sludge, hydrocarbon contaminated soils, and chlorinated
hydrocarbon by-products have all be used successfully in gasification operations.  
  
EPA believes that gasification systems processing hazardous secondary materials are
better viewed as a production or manufacturing operation rather than a hazardous
waste management activity.  To that end, EPA proposes that RCRA requirements that
attach to these operations present an unnecessary impediment to a legitimate fuel
manufacturing activity.

Although only a few facilities are now processing hazardous secondary materials in
gasification systems, the proposal may encourage great reductions in the volume of
material send for land disposal.  In the petroleum refinery industry alone, where 7-10
million tons of hazardous waste are managed in RCRA units, significant transfers of
material to gasification systems are forecast. Additional environmental benefits may
include:

   - Increased resource conservation through displacement of virgin materials used in 
     manufacturing; and
   - Reduction in energy usage and pollution from reductions in the acquisition,           
     transportation, and preparation of virgin materials used in electricity production,        
     petroleum refining, and chemical manufacturing industries.



Action

EPA proposes to revise the RCRA regulations to conditionally exclude, from the
definition of solid waste, hazardous oil-bearing secondary materials generated by the
petroleum refining industry (SIC code 2911)when the materials are processed in a
gasification system for the manufacture of synthesis gas provided:

   - System meets the definition of a gasification system;
   - System generates a synthesis gas fuel meeting the specifications of exempted 
     synthesis gas;
   - Materials generated by the gasification system are not placed on the land if they 
     exceed nonwastewater Universal Treatment Standard (UTS) for chromium, lead, 
     nickel, vanadium, arsenic, and antimony shown in the 40 CFR 268.48; and 
   - Materials are not placed on the land or speculatively accumulated prior to their 
     insertion into the gasification system.   
  
EPA is also proposing an expansion of this conditional exclusion to other hazardous
secondary materials from other industrial sectors.  To expand the exclusion, three
modifications are proposed:

   - Nonwastewater UTS constituents would increase from six to fifteen capturing the 
     entire suite of inorganic constituents regulated by RCRA in 40 CFR 268.48.   
   - Each hazardous secondary material processed in a gasification system has a total 
     organic carbon (TOC) content of at least 20%; and
   - Mercury-bearing secondary materials wastes can not be processed in the 
     gasification system.

                                  
For More Information

The Federal Register Notice, this fact sheet and related documents are avail Address written requests to: RCRA-Docket@epa.gov or RCRA Information
Center (5305W), 1200 Pennsylvania Avenue, NW, Washington, DC 20460-0001.