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Re: Who counts incineration as recycling?



Hi,

I once posited that used oil burning is a treatment on the P2Tech list serve.
In principle, I still think this is the highest status on the waste management
hierarchy it, or any material incineration,  can achieve - though with  poor
efficiencies it's more a way of disposing to the atmosphere.

But politics and regs have a different way of dealing with such theoretcial
discussion.  I think it was Ralph who reminded me at the time of the regulatory
status of used oil burning as a recycling activity .  If you wish to include
used oil burning - as energy recovery - as an appropriate response to your
query, check with the RCRA regulators to find out what records they keep on this
activity.

regards,

Rick Yoder
P2RIC
402.472.1183









"Ralph Cooper" <cooperre@flash.net> on 07/15/2000 02:54:45 PM

Please respond to "Ralph Cooper" <cooperre@flash.net>
                                                                                
                                                                                
                                                                                


                                                              
                                                              
                                                              
 To:      "Stephanie C. Davis"                                
          <ScD18@WasteReductionRemedies.com>, "NPPR Listserv" 
          <nppr@great-lakes.net>, "WRPPN listserve"           
          <p2@ucsd.edu>, "P2TECH Listserv"                    
          <p2tech@great-lakes.net>,                           
          Giuranna.Mike@epamail.epa.gov                       
                                                              
 cc:      (bcc: Rick Yoder/CBA/UNO/UNEBR)                     
                                                              
                                                              
                                                              
 Subject: Re: Who counts incineration as recycling?           
                                                              








Who counts incineration as recycling?Mike,

I do not have current data.  However, a note that the issue is not as simple as
it may seem.  At one time EPA suggested that incineration of high fuel value
wastes -- those that would provide net energy sufficient to be fuel for
incinerating other wastes -- could be considered as a reuse of the high fuel
value material, since that would offset the use of clean fuel for the
incinerator.  This is similar to allowing a cement kiln to count the use of high
fuel value waste as fuel and therefore as recycling.  In addition, cement kilns
MAY be in a position to count some of the metals and salts as recycling if it
displaces other metals and salts necessary to make good cement, such as Al, Fe
and Cl.

In the case of cement kilns, I have problems with the metals and chlorine
counting as waste reduction, but not the fuel value materials, since otherwise
the kiln would burn more coal or natural gas.

I have some problems with anything that goes into an incinerator being
considered waste reduction!!!  However, at one time, EPA called anything that
reduced land disposal "waste minimization".  After that term became politicized,
"reduction" was substituted for minimization, but the basics of the program are
the same.

Ralph E. Cooper, Ph.D., J.D.
14139 Woodstream
San Antonio, TX 78231
210-479-5490
  ----- Original Message -----
  From: Stephanie C. Davis
  To: NPPR Listserv ; WRPPN listserve ; P2TECH Listserv
  Sent: Saturday, July 15, 2000 1:28 PM
  Subject: Who counts incineration as recycling?


  The below message is forwarded from a colleague not on the listserv.
  Forward as appropriate and apologies for any duplications/multiple listserv
postings.

  PLEASE RESPOND DIRECTLY TO:     Giuranna.Mike@epamail.epa.gov
  AND CC:     ScD18@WasteReductionRemedies.com
  AND CC:     the listserv, if appropriate.
  THANKS

  -----------
  Does anyone have any information on which States or whoever count incineration
  as recycling or recovery when calculating their recycling rate?  Also  do you
  know how they calculate it?  ( as reuse of ash or as energy recovery or
  however?)

  Thanks


  Mike Giuranna
  EPA, Region III
  1650 Arch Street
  Philadelphia, PA  19103-2029
  215-814-3298
  215-814-3163 fax
  e-mail giuranna.mike@epa.gov


Title: Who counts incineration as recycling?
Mike,
 
I do not have current data.  However, a note that the issue is not as simple as it may seem.  At one time EPA suggested that incineration of high fuel value wastes -- those that would provide net energy sufficient to be fuel for incinerating other wastes -- could be considered as a reuse of the high fuel value material, since that would offset the use of clean fuel for the incinerator.  This is similar to allowing a cement kiln to count the use of high fuel value waste as fuel and therefore as recycling.  In addition, cement kilns MAY be in a position to count some of the metals and salts as recycling if it displaces other metals and salts necessary to make good cement, such as Al, Fe and Cl.
 
In the case of cement kilns, I have problems with the metals and chlorine counting as waste reduction, but not the fuel value materials, since otherwise the kiln would burn more coal or natural gas.
 
I have some problems with anything that goes into an incinerator being considered waste reduction!!!  However, at one time, EPA called anything that reduced land disposal "waste minimization".  After that term became politicized, "reduction" was substituted for minimization, but the basics of the program are the same.
 
Ralph E. Cooper, Ph.D., J.D.
14139 Woodstream
San Antonio, TX 78231
210-479-5490
----- Original Message -----
From: Stephanie C. Davis
To: NPPR Listserv ; WRPPN listserve ; P2TECH Listserv
Sent: Saturday, July 15, 2000 1:28 PM
Subject: Who counts incineration as recycling?

The below message is forwarded from a colleague not on the listserv.  
Forward as appropriate and apologies for any duplications/multiple listserv postings.

PLEASE RESPOND DIRECTLY TO:     Giuranna.Mike@epamail.epa.gov
AND CC:     ScD18@WasteReductionRemedies.com
AND CC:     the listserv, if appropriate.
THANKS

-----------
Does anyone have any information on which States or whoever count incineration
as recycling or recovery when calculating their recycling rate?  Also  do you
know how they calculate it?  ( as reuse of ash or as energy recovery or
however?)

Thanks


Mike Giuranna
EPA, Region III
1650 Arch Street
Philadelphia, PA  19103-2029
215-814-3298
215-814-3163 fax
e-mail giuranna.mike@epa.gov