—
— —
PROCEEDINGS OF
THE NATIONAL CONFERENCE ON
WASTE EXCHANGE
Sponsored by
The Florida Chamber of Commerce
The Florida State University
and
The U.S. Envir 3ntal Protection Agency
i •>-
March 8-9, 1983
Tallahassee, Florida
Edited by
Roy C. Herndon, The Florida State University
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PROCEEDINGS OF
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Property of u.
Agency L,^Y MD-1C3
A?a 2 8 1992
•,,,t\6..v'A 98101
THE NATIONAL CONFERENCE ON WASTE EXCHANGE
Sponsored by
The Florida Chamber of Commerce
The Florida State University
and
The U.S. Environmental Protection Agency
March 8-9, 1983
Tallahassee, Florida
Edited by
Roy C. Herndon, The Florida State University
U.S. EPA LIBRARY REGION 10 MATERIALS
RXDD000bclfi4
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CONTENTS
PREFACE
SUMMARY
I. Overview of the Waste Exchange Concept 1
II. Waste Materials Suitable for Exchange 29
III. Expectations of Industry and Commerce in Waste
Exchange Activity 34
IV. Cooperation Among Exchanges 40
V. RCRA Reauthorization and New Definitions
Concerning Resource Reuse 45
VI. Incentives/Barriers to Successful Exchange 52
VII. Strategies to Encourage and Facilitate
Waste Exchange 58
VIII. Legal Considerations and Legislative Trends with
Regard to Waste Exchange 62
IX. Need for a National Association for Waste Exchange
and Resource Reuse 71
Appendix A: Conference Agenda
Appendix B: List of Participants
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PREFACE
Typically conference proceedings are a collection of
papers submitted by participants. The actual contribution of
the individual participant at the conference may or may not be
reflected by the paper submitted. Nevertheless, this collec-
tion of papers is usually the product by which the success of
the conference is judged.
The real worth of a conference, however, can hardly be
measured simply in terms of the quality of the papers, since
the papers could be distributed and evaluated without having a
conference at all. The real value of a conference is to be
measured in terms of the questions, discussions, and ideas that
evolve when a group of individuals set for themselves the task
of defining and resolving a problem. It is in this spirit that the
National Conference on Waste Exchange was conceived and
delivered, and it is in this spirit that we hope it will be judged.
The Conference Proceedings have been structured in a
way which reflects the participatory nature of the conference.
We have consolidated and integrated the presentations and
comments into what we feel is an accurate reflection of the
conference activities. The first section entitled an "Overview
of the Waste Exchange Concept" contains material that is
essential for a full understanding of the conference implica-
tions. For this reason, as well as the fact that this is the first
national conference on waste exchange, we have intentionally
expanded this section to assist those not familiar with the
waste exchange concept. The other sections present the ideas,
questions, and discussions appropriate to the general topic
areas defined by the Conference Agenda (Appendix A).
It would be impossible to conduct a conference of this
kind without the combined contributions of many people at all
stages of planning and execution. Technical matters of
seating, meals, electronics and overall facilities planning were
provided by the staff of the Florida State Conference Center.
Special appreciation is extended to Ms. Suzanne Harrell and
Ms. Lori Cohen for flexibility and cooperation in all phases of
preparation. Preconference and postconference administra-
tion and clerical assistance were provided by Conference staff
and by the Institute of Science and Public Affairs at Florida
State University. Ms. Hunter Barnett and Ms. Mary Melton
deserve special mention in this regard. In addition, registra-
tion, preconference correspondence, and various other aspects
of preparation were carried out in a highly professional
manner by Ms. Rose Zongker (FSU), Ms. Geraldine Wyer
(EPA), Mr. John Moerlins (FSU) and Mr. Christopher Teaf
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(FSU). Required printing was performed by Executive Printing
Company, Tallahassee.
Many of the conference participants generously gave of
their time and energy in reviewing and commenting on the
proceedings as they were developed. Their contributions are
gratefully acknowledged. . , .
Support for the conference, both financial and otherwise,
was provided by: the Florida State University, the Florida
Chamber of Commerce, the U.S. Environmental Protection
Agency, and the Southern Waste Information Exchange.
Finally, our sincere appreciation is extended to the
moderators, panelists, and participants who shared their
experiences regarding waste exchange and resource reuse.
The conference answered many questions while at the same
time posed some new ones which will require further delibera-
tions if the concept is to continue developing. It is through a
continuous and open exchange of ideas that successes can best
be nurtured and mistakes avoided.
Roy C. Herndon, Florida State University
Editor and Conference Coordinator
Associate Editors:
Rolf P. Hill, U.S. Environmental Protection Agency
John E. Moerlins, Florida State University
Elizabeth D. Purdum, Florida State University
Christopher M. Teaf, Florida State University
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SUMMARY
The problems associated with the economical and safe
disposal of solid wastes have grown increasingly complex as
industry has developed sophisticated manufacturing processes
and provided a wide variety of products to the marketplace.
Research aimed at providing solutions to the disposal problem
has generally acknowledged that a single approach to encom-
pass disposal of all types of wastes is impractical, particularly
for hazardous wastes. Waste transfer or exchange between
firms, as an alternative to the well-established techniques of
land disposal, incineration, chemical stabilization, and neutral-
ization/detoxification, shows promise in regions which possess
the proper industrial make-up and geographic concentration of
industry.
A waste exchange can be defined as an operation that
engages in transfer of either information concerning waste
materials or the waste materials themselves. There are both
similarities and differences between this concept and the
traditional purchase or reuse of industrial by-products. In both
cases, an industrial process generates, in addition to its
principal products, some material that is not usable by the
generating company. In cases where this material has some
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inherent, recognized value, it is known as a by-product, and is
sold or reused if the value justifies the costs of transport,
handling or recycling. If the material has no typically
recognized value, it has in the past been termed a waste and is
generally discarded. The waste exchange seeks to facilitate
prospective transfers of these "wastes," the economics of
which are dependent on availability of other raw materials,
disposal costs, transport costs, and purity of the waste stream.
Several conditions explain the need for waste exchange
in industrial relations. Large companies with skilled chemical
engineers are likely to find many recycling opportunities
within their own manufacturing operations. However, the
utility of an exchange arises because even engineers in large
corporations are not likely to recognize all waste transfer
possibilities available with firms outside of their own industry.
Moreover, technical innovation to provide new uses or value in
scrap or discarded materials does not occur in all industries
simultaneously. Medium-sized or small companies often lack
the time and expertise to find reuses for the majority of their
wastes. Several variations on the basic waste exchange
concept are in operation throughout the world. These varia-
tions can be broadly classified into two groups: information
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exchanges (clearinghouses) and material exchanges. The dis-
tinction between the two categories is based on the degree to
which the exchange involves itself in the transactions between
waste generators and waste users.
The clearinghouse, in most cases, takes a passive role in
the exchange process. Its function is to inform and bring
together waste generators and waste users through a publica-
tion of some type. Referrals are initiated by publishing
listings of wastes offered and wastes wanted. The clearing-
house handles inquiries about these listings and refers the
inquirer to the listing company. All negotiations concerning
details of the potential exchange are handled directly by the
two companies.
All of the existing material exchanges are located in the
United States and are run as profit-making enterprises.
Waste exchanges were first organized in Europe where
depletion of readily available natural resources and limited
land disposal areas forced manufacturers to find alternative
sources of raw materials. The earliest exchange was started
in England during World War II, and the idea has since spread
to Scandinavia, France, Germany, Austria, Italy, Belgium, and
other areas of Europe. Exchanges have also been organized in
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Canada, Israel, and Australia. All of these foreign exchanges
are information clearinghouses and most of them are operated
by trade organizations, primarily in the chemical industry.
Several exchanges were started in the United States in
the mid-1970s. Most of these U.S. exchanges are information
clearinghouses. Material exchanges are the major innovation
in the waste exchange concept to be developed in the United
States.
Surplus materials, equipment, scrap metals, and discon-
tinued products, as well as traditional "wastes", may enter the
exchange cycle. "Investment recovery" has been used to
describe the entire process of recycling and reuse within some
industries. This term further emphasizes the point that
facilitation of waste exchange, rather than waste exchanges
per se, is the goal of this conference.
It is possible to view each segment of the materials
transfer continuum as either a catalyst or inhibitor of the
system. The optimal climate is one in which all parties
(including generators, waste exchanges, brokers, governmental
agencies, and users) are actively encouraging the concept so
that it has the greatest opportunity for success.
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In addition to the direct transfer of materials, some
firms have investigated or instituted process modifications
designed to allow for or enhance the reuse potential of by-
products generated during regular manufacturing processes.
Some of these changes can be quite modest while others
require more planning and evaluation to realize their economic
possibilities. Examples of modifications which have been
successful in the past include: substitution of reclaimed acid
for typical virgin electroplating acids; source separation and
segregation of various materials; concentration and volume
reduction; modification of raw material specifications to allow
substitution of minimally lower quality inputs; intermediate
reactions designed to modify waste stream components;
tighter process control to take advantage of by-product (not
waste) streams; education of plant management and employees
about the benefits of resource reuse.
An active role must be taken by parties in all phases of
the resource reuse cycle. Opportunities must be sought out
and recognized, good design and planning should be specifically
encouraged, and direct economic incentives for resource reuse
should be provided. Agencies in a position to do so should not
only verbally encourage exchange and resource reuse, but
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should also create financial incentives where possible, includ-
ing tax exemptions on transferred materials and facilitated
permitting for firms engaged in legitimate recycling.
Each situation involving a secondary material and its
reuse potential must be viewed in light of three specific
considerations: technical, practical, economic. Of these, the
economic factors often bear most heavily on the corporate
decision to recycle.
The issue of confidentiality remains controversial. A
strong point in its favor is the fact that confidentiality
protects the proprietary interests of generators and limits the
direct identification of specific firms which are generating a
particular material. In the case of for-profit exchanges or
brokerage services, it was judged imperative that the identity
of the source and user remain confidential in order to protect
both parties and to allow the negotiations to be brought to a
successful conclusion. Both of these points were challenged by
those who suggested that confidentiality was overdone and
that in the case of many firms, waste generation information
was already available to the public through agency waste
reporting processes. Optional confidentiality was identified as
a recent trend in some waste exchanges. Potential liability
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was identified here as a primary reason for nonparticipation by
industry in waste transfer. It was suggested that some type of
certification of recyclers be instituted to protect the user.
Even though raw material costs represent large expenditures,
and although significant savings can often be realized by the
substitution of secondary raw materials, seripus production
problems may be encountered if materials are inadequately
characterized or misrepresented.
Collection and transfer facilities could serve as consoli-
dation points for reusable materials. Legal complications
arising from the contract signed by generator and disposer,
however, often limit what can be done with a waste material
at a transfer facility. Historically, disposal firms have tended
to emphasize secure and final disposal (e.g., secure landfilling)
as the most attractive option without offering reuse as an
alternative. This protects generator, transporter, and
disposer. This situation is likely to persist in the absence of
incentives for disposal firms to alter this attitude.
Expectations of industry with regard to resource reuse
and waste transfer can be summarized in terms of four
requirements:
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1. Participation in a waste exchange must be uncom-
plicated and cost-effective. The exchange itself
must be reputable and reliable.
2. Alternatives to conventional treatment and
disposal methods which are presented by a waste
exchange must be ethical and cost-effective.
3. The exchange should have as wide an audience of
potential users as possible and should have exten-
sive contacts in the waste management field in
order to be aware of all waste management
options.
4. The generator must know where and in what form
his waste is being reused or disposed.
There are numerous examples of cooperation between
exchanges in the U.S. and abroad. However, not all exchanges
believe cooperation is in their best interest. Suggestions for
areas of potential cooperation include:
o common data base shared on regional or national
level
o trading of listings between exchanges for catalog
distribution
o network of regional contacts for information
referral
o licensing or some other formal standardization of
exchanges to ensure maintenance of quality of
service.
Other ideas were presented that would provide an
impetus to the development or expansion of waste exchanges.
One suggestion was to make the use of a broker, a waste
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exchange, a recovery facility, or an in-house treatment unit
mandatory before a generator would be allowed to go to a
disposer. Exchanges would also benefit from public informa-
tion programs concerning waste exchange and resource reuse.
Through cooperation, waste exchanges can launch a more
effective public awareness campaign, and they can also share
technical, legal and environmental information that may be
mutually beneficial.
An address by Dr. John Skinner which reviews the EPA
position regarding resource reuse in the context of solid waste
regulation is contained in Section V.
There are several impediments to exchange from the
point of view of the generator. Many generators do not
recognize opportunities for recycling nor do they know the
pertinent regulations. They may also be uncertain about
whether a particular waste is hazardous. Some generators
fear that if their waste is listed on a waste exchange, their
competitors will be able to discover secrets of their produc-
tion processes. Generators also may not want to become
involved in what they view as "another business." Potential
liability for mismanagement of waste was identified
repeatedly as a barrier to generator participation in waste
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exchanges. Unfavorable economics are another barrier to
successful exchange. Transportation difficulties are com-
pounded if the wastes are hazardous and/or transported across
state lines.
The fact that regulations are both complicated and
constantly changing, particularly with regard to the issue of
whether a substance is hazardous or not, is also a problem.
Furthermore, there are technical impediments to the recycling
of certain materials. Even if the technology is available, it
may not be economical. Related to this is the problem that,
with the exception of technical publications, no means exist
for communicating new recycling processes. The passivity of
most waste exchanges was viewed as an impediment to suc-
cessful exchange. Other barriers to successful exchange were
raised that primarily affect recyclers rather than waste
exchanges per se. The belief was expressed that excessive
regulation can put undue pressure on small businesses. The
most extreme consequences of excessive regulation were con-
sidered to be bankruptcy of small firms, unemployment, shift-
ing of the recycling field into the realm of fewer large
companies, or illegal dumping.
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The incentives for successful exchange were also
discussed. One benefit is the amount of energy saved by using
existing rather than new materials. An Argonne National
Laboratory report states that the amount of energy saved by
one waste exchange over two and one-half years was 10 x 109
BTU. It is calculated that a savings of 1012 BTU per year (the
equivalent of 100,000 barrels of oil) would result if 50
exchanges five times as large or as effective as that one
existed. A seemingly obvious incentive is the saving in cost
over the cost of disposal. Currently there are taxes levied for
producing hazardous wastes, but typically no tax incentives,
credits or advantages are given to those who recycle wastes.
Many state and federal laws have already been passed to
encourage recycling and resource reuse. Under RCRA, states
are mandated to develop programs to assist in the develop-
ment of methods of disposal of solid waste that are environ-
mentally sound and that maximize the reuse of valuable
resources. The federal government is required to provide
technical and financial assistance to the states and to encour-
age cooperation among the various levels of government and
private industry.
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Several states have passed laws to encourage alternative
approaches to waste management. Some states require coun-
ties to establish their own resource recovery facilities. It was
suggested that exchanges work with the federal, state, and
local governments to encourage the development of programs
that help to meet the spirit of existing laws. Several specific
ways for government to encourage waste exchange were
suggested.
Ways in which waste exchanges and recyclers can facili-
tate and encourage waste exchange were described. These
methods may be taken by individual organizations or they may
be taken collectively through a national association.
A variety of legislative and legal issues affect waste
exchange. Since the passage of RCRA, several bills have been
introduced to encourage resource reuse through economic
incentives. One provides tax advantages for equipment that
would reduce or eliminate waste; the other provides tax
advantages for energy recovery or savings involving industrial
waste usage. Proposed changes in the federal regulations on
the reuse and recycling of hazardous wastes will make it
easier and less expensive to recycle in some areas and more
difficult in others.
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The trend at the state level has been to tax (through
surcharges) municipal solid waste as opposed to industrial
waste. Florida is considering expansion of the exemption
from sales taxes on resource recovery equipment to all
resource recovery operations. Some states have tax laws that
apply directly to recycling of industrial waste. In New Jersey,
a tax advantage is given for waste that is recycled. A tax is
levied on generators of hazardous waste in Florida that is
related to the cost of disposing, treating, or storing of that
waste. Tax incentives remain controversial. Another legisla-
tive trend that may result in an incentive for recycling is the
idea under consideration in California, that of banning liquid
wastes in landfills.
Because federal regulations promulgated under RCRA do
not establish legal liability, possible legal problems are of
concern to anyone in the chain of custody of a hazardous
material. In recent court decisions, liability under Superfund
and RCRA has been construed as joint and several. This trend
has a potential impact on waste exchanges, although brokers
and exchanges may not be liable if they keep waste out of
their legal possession. Superfund makes provisions for -indem-
nity clauses to be entered into between parties, but these
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clauses do not insulate a party from liability. The generator
may sue the other party if the contract is broken, but the
generator may still be held liable under joint and several
liability.
Some recyclers expressed the concern that the quality of
the waste they receive may not meet the parameters specified
in the contract. A clear answer, short of extensive laboratory
testing, was not decided upon. Associated with the concern
for product quality is the perceived reputation of various
persons managing the waste. Because of joint and several
liability, generators and recyclers must be concerned about
the reputation of one another. In addition, both the generator
and the recycler need to be concerned about the credentials of
the transporter. Such a situation may encourage long-term
arrangements between firms.
Concern was expressed that there are no provisions to
recycle waste from Superfund clean-up activities, although
opportunities clearly exist for some recycling activity. Indivi-
duals with this concern should contact the EPA regional office
and that they also express their concern to EPA's Office of
Solid Waste.
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Advantages of a national association for waste exchange
were discussed in a preliminary session on the first day of the
conference. These included facilitation of communication
among members, lobbying at state and federal levels, docu-
mentation or licensing of members as legitimate operators,
and dissemination of technical, legal, and environmental infor-
mation on recycling. A national waste exchange may not be
reasonable, workable, or desirable, but a trade association
which represents state or regional exchanges could be a useful
entity. Trade associations have more effective input into the
political process than individuals. Government officials
frequently do not have the time to meet with as many
individuals as they would like, but individuals can have their
voice heard through trade associations. Associations may
provide many other useful functions in addition to lobbying.
Several tasks must be accomplished before such an
association can be established. The scope, purpose, and
function of the association must be determined. Next, it must
be decided what group will be included in the association. The
consensus seemed to be that initially the membership of the
association should be broadly defined to include all groups and
that the association develop a code of ethics. It was also
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suggested that the association include members from outside
the U.S. as well.
Representatives from several waste exchanges met in-
formally early in the final day of the conference and agreed to
exchange catalogs, investigate the standardization of waste
categories, and work toward a universal coding scheme that
would maintain user confidentiality while providing consis-
tency in listing information.
A resolution was made to form a national association
"for waste exchange and resource reuse." The session ended
with the agreement that a committee would be organized to
prepare a position paper to define tasks that need to be
accomplished. The position paper should identify the need for
and functions of the association. After these are specified,
other aspects of the association such as structure, by-laws,
membership requirements, and code of ethics may be
proposed.
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I. OVERVIEW OF THE WASTE EXCHANGE CONCEPT
Introduction
The problems associated with the economical and safe
disposal of solid wastes have grown increasingly complex as
industry has developed sophisticated manufacturing processes
and provided a wide variety of products to the marketplace.
Research aimed at providing solutions to the disposal problem
has generally acknowledged that a single approach to encom-
pass disposal of all types of wastes is impractical, particularly
for hazardous wastes. Waste transfer or exchange between
firms, as an alternative to the well-established techniques of
land disposal, incineration, chemical stabilization, and neutral-
ization/detoxification, shows promise in regions which possess
the proper industrial make-up and geographic concentration of
industry. It will not eliminate the need for treatment and
disposal operations, but it can provide a valuable option within
the waste management picture. The generator benefits from
the potential sale of the waste material as well as the avoided
disposal cost, and the user benefits from the reduced raw
material costs. More subjective social benefits include
decreased natural resource consumption, decreased energy
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required for raw material processing, and decreased require-
ments for traditional disposal or treatment facilities.
Transfer of by-products or surplus material with recog-
nized value has been an industry practice for some time.
However, maximum success of the waste exchange concept
often involves a third party (or transfer agent) to coordinate
referrals, to provide technical information, and to maintain
confidentiality if necessary. This third party can assist in
recognizing potential uses of products, facilitating contact
between generators and potential users who are not familiar
with each others' industries, and providing confidentiality to
generators who might be reluctant to reveal process informa-
tion.
A waste exchange can be defined as an operation that
engages in transfer of either information concerning waste
materials or the waste materials themselves. There are both
similarities and differences between this concept and the
traditional purchase or reuse of industrial by-products. In both
cases, an industrial process generates, in addition to its
principal products, some material that is not usable by the
generating company. In cases where this material has some
inherent, recognized value, it is known as a by-product, and is
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sold or reused if the value justifies the costs of transport,
handling, or recycling. If the material has no typically
recognized value, it has in the past been termed a waste and is
generally discarded. The waste exchange seeks to facilitate
prospective transfers of these "wastes," the economics of
which are dependent on availability of other raw materials,
disposal costs, transport costs, and purity of the waste stream.
Several conditions in industry emphasize the need for
waste exchanges. Large companies with skilled chemical
engineers are likely to find many recyling opportunities within
their own manufacturing operations. However, the utility of
an exchange arises because even engineers in large corpora-
tions are not likely to recognize all waste transfer possibilities
available with firms outside of their own industry. Moreover,
technical innovation to provide new uses or value in scrap or
discarded materials does not occur in all industries simultan-
eously. Finally, medium-sized or small companies often lack
the time and expertise to find reuses for the majority of their
wastes.
Types of Waste Exchanges
Waste exchanges can be divided into two basic types,
information exchanges (or clearinghouses) and material ex-
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changes. Of course, a combination of these types of services
is also possible. There are some similarities in operation
between the categories; however, the two types differ funda-
mentally in the degree of involvement which the exchange has
in interactions between waste generators and waste users.
The clearinghouse type of waste exchange typically
takes a relatively passive role in the exchange process. The
function of the clearinghouse is to inform and bring together
waste generators and waste users through publication of some
type of catalog and through other means such as phone or
computer communication. Once this referral is made and the
contact between groups is established, the clearinghouse
usually takes no further action. Figure 1-1 summarizes this
relationship.
Referrals are initiated by publishing detailed descrip-
tions of wastes offered and wastes wanted. These listings are
circulated in a variety of clearinghouse publication formats.
The clearinghouse handles inquiries about these listings and
refers the inquirer to the listing company. All negotiations
concerning details of the potential transfer are then handled
directly by the two companies. Materials commonly listed by
information exchanges include acids and alkalis, solvents, oils,
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Figure 1-1
SAMPLE INFORMATION CLEARINGHOUSE OPERATION
Inquiry
Offer
Disposal
Referral
Referral
Agree
Not Agree
Oeion'ication
Lan
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surplus chemicals, metals, paper and wood, plastics, and
rubber products. In addition, categories of waste management
services available may be included to provide catalog users
with information on other opportunities such as transport,
disposal, laboratory analysis, and recycling of waste materials.
Several areas of concern are common to information
clearinghouse operations. One of the most important is
maintenance of confidentiality for the listing firms. Many
companies are hesitant to identify themselves or release
specific information about their waste streams. The reason is
that, in many cases, details of manufacturing processes,
problems, and production rates can be deduced from waste
stream data. This information may be valuable to a firm's
competitors or to governmental agencies interested in the
enforcement of regulations. Whether this is a legitimate
concern is unclear, as the information can often be obtained in
other ways. However, many firms identify this concern for
confidentiality as an area of primary interest in initial
contacts with a waste exchange.
In order to protect the confidentiality of companies
which submit listings, various coding systems have been de-
vised. These codes provide general information about the type
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and amount of waste involved, the geographic location, and
the frequency of the waste's availability. These coded details
are usually sufficient to allow a potential buyer to decide
whether to seek further information through the exchange. In
addition, a system of universal coding has been proposed which
incorporates valuable information about generator, location,
material and volume in a single string of digits. Such a
system, if instituted, would encourage cooperation among
waste exchanges by making the various information bases
compatible. However, its use presently is not widespread.
Several exchanges now publish selected listings from other
waste exchanges to facilitate potential transfers. Contacts
are generally referred to the waste exchange from which the
listing originated.
Accumulation of listings with little or no market value is
a second problem common to waste exchanges that have been
in operation for some time. Many clearinghouses have found
that the majority of successful waste transfers occur early in
the history of the exchange. As markets for specific types of
wastes develop through waste exchange referrals, the number
of successful transfers is often reduced. This frequently
leaves only two categories:
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• listed materials that are difficult to exchange, and
• episodic listings of new, potentially marketable
waste materials.
Due to the inherently passive nature of the information
exchange, assessing the efficiency of its efforts is a third
difficulty. Once a referral is made the clearinghouse usually
takes no further action in the exchange process. Therefore, it
is difficult for an exchange to determine whether a referral
was successful. Some clearinghouses conduct surveys to
previous listers in order to determine the number of successful
exchanges that have occurred. However, low response rates
on most of these mail surveys result in incomplete data. One
United States clearinghouse estimates ten to fifteen percent
of their listings result in successful transfers. A recent survey
of all firms listing with the Southern Waste Information
Exchange indicates that the potential for transfer depends
largely on the individual case. Further, some categories of
waste have much better success rates than others.
It has been suggested that these three problems, and
perhaps others inherent in the clearinghouse process, can be
reduced by more direct personal interaction between the
clearinghouse staff and participating firms—in short, an
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active rather than a passive information exchange. There are
several benefits to active participation. For example, industry
executives may have more confidence in the ability of a listing
service to keep information secure if they know and trust the
exchange personnel. Once this confidence has been developed
and a good reputation established, less resistance should be
encountered in convincing firms to list their wastes. For the
same reason, more cooperation in assessing the success of the
clearinghouse is usually gained as a result of this more
personal interaction with active firms.
Clearinghouses receive financial support from a variety
of sources. These sources include non-profit industrial trade
associations, chambers of commerce, universities, and other
governmental entities. In this situation, the clearinghouse
becomes an additional service offered to members and is
supported in part by membership dues, or, in some cases, a
surcharge is added to the dues of those members using the
service. Support through an existing organization has the
benefit of reducing operating costs of the exchange in several
ways:
1) managerial, technical, and clerical staff can
operate the exchange as a part of their other
duties,
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2) additional office space is usually not necessary,
3) technical advisors are often readily accessible,
4) if the association publishes a periodical, some
printing facilities and distribution lists may already
be available.
Many exchanges also charge a nominal fee for listing
materials or services with the exchange. These charges are
used to cover direct costs of catalog publication. This
financial arrangement has the advantage of spreading the base
of support over the most actively participating firms and does
not place undue burdens on any one group. It also allows
partial support by a variety of trade associations or chamber
of commerce-type groups so that the membership of all
organizations may benefit directly while each only pays a
small share of the operating costs of the exchange.
A few information clearinghouses operate as self-
supporting, profit-oriented entities. These are generally
operated in a much more active manner than the non-profit
exchanges. This type of operation requires more managerial
time and talent to attract subscribers and users. Furthermore,
additional staff time is needed, and higher office costs are
usually incurred. A commission on successful transfers is
10
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usually charged to recover these costs. Services of this type
are rare at this time.
Few government subsidized and operated information
clearinghouses exist, although government funds have assisted
in the initiation of some exchanges. This is largely due to the
perceived confidentiality problem. Many companies feel that
public access to governmental agency information precludes
confidentiality and security of information. Also govern-
mental support may lead users to think that the information
they provide could be used for regulatory purposes. This
concern was not shared by all participants.
Material Exchange
Material exchanges differ from information exchanges in
that they act as a direct brokerage service between waste
generators and waste users (Figure 1-2). The degree of
involvement in waste transactions varies widely among
material exchanges. Some act as an agent, actively seeking a
buyer or seller for a particular material. Other material
exchanges take possession of the material and perform what-
ever functions are required to complete a transfer. Analysis,
reprocessing, repackaging, or transport are sometimes sub-
contracted out to other companies.
11
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Figurel-2
SAMPLE MATERIALS EXCHANGE OPERATION
Referral
Referral
Offer
Inquiry
Disposal
Sale
OelOmtiejttOP
Purchase
User
Packaging
Marketing
Transport
Materials
Exchange
No
Processing
Processing
User Requests
Waste
Generator Produces
Waste
-------
Existing material exchanges tend to accept and transfer
a more restricted range of wastes than information clearing-
houses, although this is clearly dependent on market factors at
any given time. The exchange must be able to identify wastes
with sufficient value in order to cover costs and provide a
profit. TOs judgment is critical to the survival of the
exchange. The wrong decisions may cause a problem similar
to that faced by information clearinghouses: that is, accumu-
lation of non-transferable inventory. This situation is more
serious for the material exchanges, however, as it stands to
incur substantial costs (due primarily to the time spent trying
to move the material) on storage of these accumulated
untransferable wastes.
The fixed costs of operating a material exchange are
typically higher than those of a clearinghouse. Often a more
comprehensive waste handling service is offered and, as a
result, a greater amount of time is required to manage the
technical, legal, and business operations. Sometimes expen-
sive waste handling equipment must be purchased and main-
tained.
There are only a few material exchanges in operation at
this time. All of these are located in the United States and
13
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are run as profit-making enterprises. All of these exchanges
charge a commission or buy the material outright based on the
estimated value of a successful transfer.
Dual Capability Exchanges
Another possibility includes the potential for dual-capa-
bility waste exchanges, which combine the advantages of both
clearinghouses and pure materials exchanges. An operation of
this kind might be run by a non-profit organization with a
large information handling component and a limited material
handling component.
The materials handling component might be a reason to
devise innovative ways of using or combining wastes and
modifying production processes. This would require an experi-
enced and creative staff of technical and business advisors.
The information handling component could be expanded from
making simple referrals to developing a broad base of reput-
able subcontractors that could be contacted when necessary.
These subcontractors would be in such occupations as trans-
portation, laboratory analysis, reprocessing, and other related
fields. This represents an expanded version of the capabilities
of some current clearinghouse operators. Cooperation
between clearinghouse and brokerage services in a geographic
14
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region could provide functionally the same range of services
by combining a large volume information component with a
versatile well-coordinated service component available by
direct referral.
Historical Overview of Waste Exchanges
The following discussion presents an overview of the
development of waste exchanges in both the United States and
other countries as a result of a survey conducted in
1980-1981. A limited amount of specific information is
included in order to highlight significant developments in
foreign waste exchange operations. More detailed information
on each of the exchanges mentioned can be found in Table 1-1.
Foreign Exchanges
One of the earliest waste exchanges was established in
Britain in 1942. This exchange, the National Industrial
Materials Recovery Association (NIMRA), was organized to
conserve materials during World War II. It was run by the
British government until 1956 when an industrial association
assumed control. NIMRA operates on a non-confidential basis
and mainly handles surplus or unused equipment. Activities
have decreased substantially in recent years.
15
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TABLE 1-1
CHARACTERISTICS OP EUROPEAN AND CANADIAN WASTE EXCHANGES
Foreign
Exchange
Service
Area
Initiation
Govt.
Funding
Confidential
Sub-
scription
Fee
Approxi mate
Circulation
Frequency
of
Publication
CWME
(Canada)
Inter-
national
11/77
YES
YES
YES
5,700
Bi monthly
IKWME
(UK.)
National
1974-1980
NO
YES
YES
6,000
Quarterly
NIMRA
(UJC.)
National
1942
NO
NO
YES
2,000
Monthly
SWE
(Switzerland)
National
2/1973
NO
YES
NO
600
Monthly
CUE
(Austria)
National
J/1973
NO
YES
NO
—
Monthly
FWE
(Austria)
National
7/1974
—
NO
—
—
Monthly
NWE
(Sweden)
Inter-
national
11/1973
NO
YES
Annual
Duea
—
Quarterly
TWME
(Italy)
National
5/1971
NO
YES
NO
3,000
Quarterly
AN1C
(Italy)
National
3/1973
NO
—
YES
—
Weekly
WBI
(Israel)
National
9/1976
YES
YES
NO
—
Monthly
MWDA
(Australia)
Regional
3/1977
YES
YES
NO
—
Quarterly
IWES
(Auatralla)
Regional
2/1979
YES
YES
NO
—
Quarterly
ANRED
(France)
National
1976
YES
YES
NO
Over
25,000
Quarterly
VCI
(Oar many)
Inter-
nationa)
1973
NO
YES
NO
--
Bimonthly
DJHT
(Germany)
inter-
national
1974
NO
YES
YES
700,000
Monthly
VKCI
(Netherlands)
National
4/1972
NO
YES
NO
—
Monthly
FICB
(Belgium)
National
11/1972
NO
YES
YES
1,000
Semi-weekly
OBBA
(Belgium)
National
12/1979
YES
YES
NO
1,000
Bimonthly
16
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In 1972, two European clearinghouses were formed. The
Dutch exchange, VNCI, was established in April 1972 by the
Association of Netherlands Chemical Industries. VNCI esti-
mates 30 percent of all listings result in successful transfers.
In November 1972, the Federation of Belgian Chemical Indus-
tries initiated a clearinghouse, the Federation des Industries
Chemique de Belgique (FICB). This exchange rapidly notifies
potential customers of available wastes. FICB publishes
listings three times per week. Both of these exchanges were
organized specifically to serve the chemical industry.
Several European information exchanges began opera-
tions in 1973. Among these are the German Association of
Chemical Industries (VCI) exchange, the National Association
of Chemical Industries (ANIC) exchange in Italy, and
exchanges in Austria and Switzerland. All of these exchanges
are sponsored and operated by industrial organizations.
The Nordic Waste Exchange was also established in 1973.
This clearinghouse is a cooperative effort of the Federations
of Industry in the four Scandinavian countries: Denmark,
Norway, Finland, and Sweden. Part of the funding during the
early years of the Nordic Exchange came from the Nordic
intergovernmental organization, Nordisk Industrifond. The
17
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federations of industry of these four countries now completely
subsidize the exchange.
With the exception of NIMRA, all of the above clearing-
houses, including the German Deutscher Industrie-und Handel-
stag (DIHT, established in 1974), publish listings in the German
monthly trade journal, Chemical Industry. This assures a
broad circulation beyond the membership of the sponsoring
trade organization. Most of these exchanges also publish their
listings in a clearinghouse newsletter or bulletin that is sent to
that membership only.
An information exchange was started in Canada in 1973.
Three organizations have managed this exchange during its
history. It is currently operated by Ontario Research, a non-
profit organization. The exchange has received some govern-
ment sponsorship. This clearinghouse handles information on
all types of wastes and equipment from all geographical areas
in Canada. It is one of the few exchanges that actively
pursues information on the success of its efforts. In two years
of operation under Ontario Research (1979-1981), the
Canadian exchange estimated that 95,000 tons of waste per
year were successfully transferred. The estimated value of
this Annual transfer is approximately 3.7 million Canadian
18
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dollars. Organic compounds and metals were the materials
transferred with greatest success.
Three more clearinghouses were established in Europe in
1974. The West German exchange (DIHT) and the Austrian
Federal Waste Exchange were begun by their respective
national chambers of commerce. The third exchange was the
United Kingdom Waste Exchange (UKWME). This exchange
tried to initiate an extensive computer data handling program
under government funding. Attempts were made to make the
exchange self sufficient. Failure of this endeavor resulted in
removal of the government subsidy in January, 1980 and,
hence its termination. The exchange may be revived by an
industrial organization. UKWME compiled extensive data on
successful waste transfers from 1974 to 1979.
In late 1976, the Israeli Ministry of Industry, Commerce
and Tourism started an information referral service for waste
generators and users. The service also provides analytical,
reprocessing, and other consulting services. Their published
waste listings are distributed to all waste-producing facilities
in the country.
Hie Metropolitan Waste Disposal Authority in New South
Wales, Australia, introduced a waste exchange in 1977. Hiis
19
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exchange avoids listing equipment and materials with esta-
blished markets. Confidentiality is maintained, but listing
firms are required to notify the exchange of successful trans-
fers,
A waste exchange was started in 1978 by the Turin,
Italy, Chamber of Commerce. The exchange publishes a
bulletin (circulated free of charge to all Italian Chamber of
Commerce members and all industrial unions) that has
recently begun to include pertinent articles, announcements,
and legislative actions, as well as waste listings.
Three more exchanges began operation in 1978. The
Office Beige de L'Economie et de L'Agriculture (OBEA) ex-
change in Belgium was started as a two-year experiment by
the government. A second Australian exchange was started in
the state of Victoria and is very similar to the New South
Wales exchange. The third organization was begun in France.
This operation is actually a governmental agency established
as part of a X975 law. The National Agency for the Recovery
and Elimination of Waste (ANRED) was one of the results of
this law and is responsible for setting up six regional waste
exchanges. The directors of the agency are representatives of
20
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central and local governments, industry, and environmental
and consumer groups.
United States Exchanges
The following section highlights the development of
waste exchanges in the United States.
The Union Carbide Corporation set up its Investment
Recovery Department in 1964 to market surplus equipment
and materials. This department was expanded in 1969 to
include chemicals, metals, and other wastes. The Department
looks for transfers within the Union Carbide Corporation or,
secondarily, sales outside the corporation. This operation is
not strictly an exchange in that wastes from other organiza-
tions are not accepted for transfer. However, it does repre-
sent the introduction of the materials exchange concept and
the marketing of wastes to reduce disposal or storage costs.
In 1973, Zero Waste Systems of California was founded
as a waste information exchange. ZWS was later reorganized
into a material exchange. The company takes possession of
wastes (usually chemicals) and reprocesses or repackages them
to meet specific market needs.
Another material exchange, The Exchange, was started
In 1975 in Boston. The Exchange was a profit-making enter-
21
-------
prise which did not take possession of wastes. It has since
ceased operation.
The initial clearinghouse in the United States was
started in St. Louis in 1975 by the St. Louis Regional
Commerce and Growth Association. Ri 1979 the Kansas City
Chamber of Commerce joined in co-sponsorship and the name
was changed to the Midwest Industrial Waste Exchange
(MIWE). Subsequently, several smaller midwestern waste
exchanges have joined operations with the MIWE.
Two information exchanges were started in 1976. One
was operated by the Center for Industrial Research and
Service of Iowa State University, and has since joined MIWE.
The other is the Georgia Waste Exchange, which was initially
organized by the Georgia Department of Natural Resources.
It has since been taken over by the Georgia Business and
Industry Association.
A material exchange was also started in 1976 in Illinois.
The American Chemical Exchange (ACE) is a profit-making
enterprise primarily dealing in virgin materials. ACE also
handles specific types of waste materials.
Four clearinghouses were started in 1977. The Houston
Chamber of Commerce organized the Chemical Recycle Infor-
22
-------
mation Program to help conserve resources and reduce pollu-
tion. The program concentrates on chemical wastes. The
Western Environmental Trade Organization of Washington (a
private non-profit labor/business association) started the
Information Center for Waste Exchange in Seattle. The
Industrial Waste Information Exchange was founded by the
Columbus, Ohio Industrial Association. The Columbus ex-
change is small due to the limited number of industries and
association members in the Columbus area. The fourth
exchange was organized as a joint effort between the Minne-
sota Association of Commerce and Industry and Technotec (a
technology exchange service of Control Data Corporation).
Most of these clearinghouses accept all kinds of waste
materials for listing and operate in the passive manner usually
found in information exchanges.
The EnKarn Research Corporation of Albany, New York
was also established in 1977. This is a material exchange that
handles a limited information referral service. EnKarn acts as
an agent for sellers of wastes as well as product or equipment
surpluses.
In 1978, information clearinghouses were set up in New
Jersey and Indiana. The New Jersey exchange is located in
23
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Newark and is sponsored and operated by the State Chamber
of Commerce. The Indiana exchange is operated by Environ-
mental Quality Control, Inc., a non-profit corporation based in
Indianapolis in cooperation with the MIWE.
In late 1978, the World Association for Solid Waste
Transfer and Exchange (WASTE) began operation in San
Francisco, California. This is a non-profit organization that
provides a comprehensive waste information service.
Computerized files of several types of waste and waste
management information are maintained. Although the ser-
vice is still incorporated, the central function has moved to
Connecticut and the name has been changed to the "World
Association for Safe Transfer and Exchange." At the time of
this writing, activity has declined considerably due to high
costs.
The Mecklenburg County Waste Exchange was initiated
in North Carolina in 1978 and serviced firms within a 200-mile
radius of that county. In 1981, sponsorship of this exchange
was transferred to the Urban Institute at the University of
North Carolina-Charlotte and service was expanded to include
all of North Carolina and South Carolina. This change in
sponsorship formed the Piedmont Waste Exchange.
24
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The Process Industries Division of the American Alliance
of Resources Recovery Interests, Inc. started an Industrial
Waste Information Exchange in March, 1979. Assistance, but
no funding, was provided by the New York State Department
of Commerce. The exchange was supported by membership
dues and listing fees. Its operation has been taken over by the
Northeast Industrial Waste Exchange.
The Ohio Resource Exchange (ORE) of Cleveland, Ohio,
a materials exchange, was founded in May, 1979. This was a
profit-making organization that specialized in hazardous and
potentially hazardous wastes. It is no longer in business.
In 1980 several exchanges were initiated including the
Florida Waste Information Exchange (FWIX), which regional-
ized its operations in 1982 to become the Southern Waste
Information Exchange serving the southern United States. Hie
Pennsylvania Waste Exchange (now operating through the
Northeast Industrial Waste Exchange) and the Tennessee Waste
Exchange also began operation in 1980. Formed in 1980, the
New England Materials Exchange in Kennebunk, Maine, was a
for-profit operation coordinated by a private analytical
laboratory, initially set up as a service to clients. A change in
25
-------
operation has taken place and it is now operated in conjunction
with a board of representatives from various local industries.
1CM Chemical Corporation, a materials brokerage
service based in Jacksonville, Florida, initiated operations in
1981. The Colorado Waste Exchange in Denver, a clearing-
house and a for profit exchange operated by Pacific Environ-
mental Service, began operations in 1981. The Northeast
Industrial Waste Exchange, started in 1981 by the Manufac-
turers Association of Central New York and the Central New
York Regional Planning and Development Board, serves the
northeastern United States. Also initiated in 1981 but since
terminated was the National Waste Exchange based in Silver
Spring, Pennsylvania. The Great Lakes Regional Waste
Exchange recently (1982) began serving industry in the
Michigan area.
Other waste exchanges which have been formed since
1980 include the Atlantic Coast Exchange (North Carolina),
the Virginia Waste Exchange, and the California Waste
Exchange.
26
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Comparison of Development of United States and Foreign
Exchanges
When comparing the existing waste exchange organiza-
tions in the United States with those of other countries,
several features are evident. These features include many
similarities and a few significant differences.
Most apparent is the longer history of European waste
exchanges. The idea originated in Europe and was first
applied on a wide scale there. This is probably the result of
smaller reserves of raw materials and limited land disposal
areas in most European countries compared with the available
resources in the United States. It has only been within the last
few years that the combined pressures of environmental
protection and growing scarcity of raw materials have induced
industries in the United States to seek alternative sources of
materials for manufacturing processes. The waste exchange
provides one alternative.
Many operational similarities are observed between
European and American information clearinghouses. Nearly
all information exchanges, whether American or European,
have the same basic structure. They are generally operated
in a passive manner, usually only making referrals, not partici-
27
-------
pating in transfer negotiations. Most preserve the confiden-
tiality of listing companies by coding published information
and requiring written inquiries. The majority of clearing-
houses are run by trade organizations or chambers of
commerce.
The longer history, and, therefore, experience of
European clearinghouses is probably why most innovations
have occurred in the European operations. Such things as the
use of computers, cooperation with exchanges in other
countries, active pursuit of referral success, and frequent
updating of listings were all started in Europe. These ideas
have not been applied equally by all clearinghouses, however.
Probably the most significant difference in the waste
exchange concept to be found in the United States is the
materials exchange. These profit-making waste brokerages
are absent in Europe. The profit motive clearly provides
incentive to the exchange to actively seek new uses for wastes
that would normally be discarded.
28
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II. WASTE MATERIALS SUITABLE FOR EXCHANGE
Although the section title suggests only recovery of
discarded materials, the recycling of other commodities is also
a potential resource for industry. A more accurate term
might be "Investment Recovery" because the concept of
resource reuse can easily be applied to surplus equipment,
unused supplies, and discontinued products as well as wastes
traditionally requiring disposal. For this reason, a primary
emphasis of this section is how to facilitate or enhance waste
exchange, rather than how to improve operations of waste
exchanges ger se.
Overcoming the existing lack of knowledge concerning
waste management alternatives is necessary in order to get
generators and users or brokers together for their mutual
benefit. It is possible to view each segment of the materials
transfer continuum as either a catalyst or inhibitor of the
system. The optimal situation is one in which all parties
(including generators, waste exchanges, brokers, governmental
agencies, and users) are actively favoring the concept so that
it has the greatest opportunity for success.
29
-------
The universe of potentially transferable materials is
large. The following is a list of items identified by conference
participants as materials known to have potential value. They
can be grouped in a variety of ways; however, no groupings
were made for purposes of this document.
Solvents (chlorinated, other)
Used oils
Alkali (greater than 10% caustic)
Etching and electroplating solutions
Circuit boards
Pickling acids and other acids
Phenols
Paints
Inks
Trap grease (also vegetable oil skimmings and meat oil)
Laboratory reagents
Metal sludges (and in solution)
Precious metals
Spent catalysts
Auto batteries
Plastics
Autombile tires
Textile scrap
Paper and wood waste
Glass
Pressurized gas cylinders
Vegetable cuttings
Seafood processing waste
Municipal solid waste
Industrial sludge
Industrial waste water
Drums and other metal or plastic containers
Waste hydrocarbons
Caustic soda
Popcorn
Wood pallets
Organic and inorganic chemicals (off-grade, obsolete, or
in leaking containers)
30
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Carbon/graphite
Mercury
In addition to the direct transfer of some of these
materials, some firms have investigated or instituted some
process modifications designed to allow for or enhance the
reuse potential of by-products generated during regular manu-
facturing processes. Some of these changes can be quite
modest while others require more planning and evaluation to
realize their economic possibilities. Examples of modifica-
tions which have been successful in the past include: substitu-
tion of reclaimed nitric acid for typical virgin electroplating
acids; source separation and segregation of various materials;
concentration and volume reduction; modification of raw
material specifications to allow substitution of minimally
lower quality inputs; intermediate reactions designed to modi-
fy waste stream components; tighter process control to take
advantage of by-product (not waste) streams; education of
plant management and employees about the benefits of re-
source reuse.
In-plant education is probably the most important step in
the recycling process since opportunities for resource reuse
often are not recognized until they are pointed out. Waste
31
-------
exchanges, brokerage firms, and in-house investment recovery
departments can all play a role in educating generators and
potential users. Personnel from the waste exchange, broker-
age firm, or in-house investment recovery department should
visit the generator's facility. During a site visit, the broker or
in-house investment recovery specialist can look for materials
currently being stored or disposed of. In addition potential
recycling opportunities may exist through, for example, energy
recovery, material recovery, or substitution for raw materials
or other process materials. Following this, it is necessary to
provide the generator with cost-effective and technical means
by which to recycle his materials. This requires expertise in
consultation with industry which could be a service provided
by waste exchanges. Such a plan will help to overcome
mistrust and fear of future liability on the part of the
generator. Also, regulatory agencies should clarify their
positions concerning waste transfer. This means that agencies
in a position to do so should not only verbally encourage
exchange and resource reuse, but should also create financial
incentives where possible, including tax exemptions on trans-
ferred materials and facilitated permitting for firms engaged
in legitimate recycling.
32
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In summary, an active role must be taken by parties in
all phases of the resource reuse cycle. Opportunities must be
sought out and recognized, good design and planning should be
specifically encouraged, and direct economic incentives should
be provided. It is in this way that generators can be
motivated, users can be located, and environmentally sound
alternatives to traditional waste management practices can be
encouraged.
33
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III. EXPECTATIONS OF INDUSTRY AND COMMERCE
IN WASTE EXCHANGE ACTIVITY
A primary objective of any activity that promotes and
encourages resource reuse is to increase the number and
magnitude of transactions of secondary materials. As pointed
out in Section I two basic types of exchanges are currently in
operation: passive and active. Passive exchanges function
primarily by distributing a catalog of available and wanted
wastes to an audience of potential suppliers and users. Active
exchanges search for materials, sellers, and buyers. Regard-
less of the nature of such an organization, members of
industry and commerce have requirements that influence their
decisions whether to participate in a waste exchange and to
what extent their participation is appropriate. Each situation
involving a secondary material and its reuse potential must be
viewed in the light of three specific considerations before a
decision is made to recycle:
1. Technical - At the -production end, aspects of
process modification and segregation must not be
too burdensome. At the user end, process modifi-
cation must be cost effective and the purity,
consistency, volume, and regularity of the supply
34
-------
must meet specifications. This is typically the
most well-defined step and one where the initial
and most severe obstacles are encountered.
2. Practical - From a convenience standpoint, does
the changeover in suppliers and comparative novel-
ty of the concept discourage a firm from partici-
pating? This may be an area where meetings
between plant management and waste exchange
personnel can help in resolving some of these
concerns. Does concern for liability influence the
decision to participate?
3. Economic - Do the costs of process modification,
costs of transport, advertising for a source or user
of the material, and increased inconvenience of
using secondary raw materials justify the cost
savings realized? The answers to these questions
will influence whether or not a firm will pursue
further the solution to the technical and practical
problems.
Many-comments were made during this session regarding
the needs and expectations of firms investigating resource
reuse, particularly through established waste exchanges. The
35
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majority of the questions and comments concerned confi-
dentiality of information, generator liability and its limita-
tions, reasons for reluctance to participate in waste exchange,
and suggestions on how to make the system operate to the
benefit of industry.
The issue of confidentiality remains controversial. Al-
though most exchanges maintain confidentiality as a general
policy, many representatives at the conference expressed the
opinion that perhaps it was unnecessary. A strong point in its
favor is the fact that confidentiality protects the proprietary
interests of generators and limits the direct knowledge of
which firms are generating a particular material. In the case
of for-profit exchanges or brokerage services, it is imperative
that secrecy be maintained in order to allow negotiations,
including discussions of fees, to be brought to successful
conclusions. Both of these points, though, were challenged by
those who suggested that confidentiality was not that impor-
tant. For many firms, waste information reported to EPA and
state agencies already contains extensive information on
waste generation available to the public. In response to the
comment that a generator would like to select those firms
with which he does business and therefore requires confiden-
36
-------
tiality from a waste exchange, it was suggested that optional
confidentiality be instituted. This has been a recent trend in
some waste exchanges.
Although liability was discussed at several junctures
during the sessions, it was identified here as the primary
reason for nonparticipation by industry in waste transfer.
Firms were concerned with problems involving use of waste
materials as secondary raw materials and subsequent difficul-
ties if incidents occurred as a result of transport or storage of
the materials for which they might become liable under
existing regulations. Anyone transferring a waste should
inspect and audit potential users of the waste to ensure that
the intended uses are legitimate and are being carried out. It
was also suggested that some type of certification of recyclers
be instituted. One panel member reported that a recent
informal survey of large Florida firms also identified uncer-
tainty of quality and frequency of supply as important reasons
for reluctance to participate in waste transfer. Even though
raw material costs represent large expenditures, and though
significant savings can often be realized by the substitution of
secondary raw materials, serious production problems may be
37
-------
encountered if materials are inadequately characterized or
misrepresented.
It was suggested that transfer facilities, which act as
collection points enroute for treatment or disposal facilities,
could serve as sources for reusable materials. There are
several reasons, however, why this may not be possible.
Generator storage limitations often preclude the sufficient
accumulation of valuable materials so that they can be
exchanged in the first place. In the past, firms also have not
typically known enough about the precise constituents of their
waste stream to allow consolidation at a transfer facility.
Consequently, analysis would need to be carried out at the
transfer facility since it may not be possible to arrange an
exchange based on generator information alone. Legal compli-
cations arising from the contract signed by generator and
disposer, however, often limit what can be done with a waste
material at a transfer facility. Historically, disposal firms
have tended to emphasize secure and final disposal (e.g.,
secure landfilling) as the most attractive option without
offering reuse as an alternative. Some participants believed
that this protects generator, transporter, and disposer from
continuing liability, while others said that liability could be
38
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reduced by recycling. All things considered, neither option is
without some liability. The disposal option, however, is likely
to persist in the absence of incentives for disposal firms to
alter this attitude.
The expectations of industry with regard to resource
reuse and waste transfer, particularly through waste ex-
changes, can be summarized in terms of three requirements:
1. Participation in the exchange must be uncompli-
cated and cost-effective. The exchange itself
must be reputable and reliable.
2. Alternatives to conventional treatment and
disposal methods which are presented by a waste
exchange must be ethical and cost-effective.
3. The exchange should have as wide an audience of
potential users as possible. The exchange should
also have extensive contacts in the waste manage-
ment field in order to be aware of all waste man-
agement options.
The education of generators and users about available oppor-
tunities for resource reuse, as well as liability considerations,
were identified by participants as major concerns in the
promotion of resource reuse and waste exchange.
39
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IV. COOPERATION AMONG EXCHANGES
The session began with the question "is cooperation
among exchanges the key to effective service"? Because not
everyone who operates a waste exchange believes cooperation
is in their best interest, the question was later modified to
¦"what form of cooperation is appropriate for the various
exchanges and what forms of cooperation can be beneficial to
all waste exchanges?"
There are currently numerous examples of cooperation
among waste exchanges, both in the United States and abroad.
For example, in Germany the magazine Chemical Industry lists
items from the waste exchanges of many other European
countries. The Great Lakes Regional Waste Exchange in
Michigan lists, in the magazine Great Lakes Waste and Pollu-
tion Review (published by the Waste Systems Institute of
Michigan), wastes from other exchanges operating in the six-
state region and in neighboring Canadian provinces. Interested
parties are referred to the exchange where the listings origi-
nated.
Ways to make exchanges more efficient and to increase
cooperation among them were discussed. Simply publishing a
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catalog of listings quarterly or every six months is considered
too infrequent for many potential waste exchange users.
Generators, for example, may not have the facilities to store
the waste for long periods of time. Furthermore, if the waste
is hazardous, after 90 days generators are subject to regula-
tion under RCRA as a storage facility. EPA's proposed rule
regarding the definition of "solid waste" which was discussed
in Section V of these proceedings may change this require-
ment. The view was expressed that people should be able to
list wastes and to get listings of available wastes more
immediately—by telephone or through a modem, which could
be used to provide a computer printout* If exchanges cannot
afford to have a person answer the phone, it was suggested
that an answering service be used.
A common data base established and shared on a
regional, national, or even international level would be
extremely useful insofar as it would enlarge the potential
market and lead to more successful exchanges. It was pointed
out that the World Association for the Safe Transfer and
Exchange (WASTE) already has the software in place for such
a data base. Waste exchanges could also tie into existing
computerized data bases maintained by regulatory agencies
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and private businesses to search waste streams for recyclable
materials. Use of a computerized data base by and among
waste exchanges raised a more fundamental issue: there is no
uniform system for listing wastes—different exchanges use
different systems of classifying and listing wastes. The need
for a standard classification system must be addressed prior to
establishing a common data base among exchanges. The 1980
EPA study entitled Waste Exchanges: Background Information
(SW 887.1) was suggested as a possible source for standardiza-
tion.
Communication among exchanges could be facilitated by
establishing a network of regional contacts within which
information could be exchanged. Network members would
inform each other of their areas of specialization so that
referrals could be made when appropriate. Using, for
example, the model of a real estate licensing service, a similar
service might be developed to ensure that member exchanges
are reliable and responsible. Such a licensing service could
help prevent disreputable exchanges from inpugning the repu-
tations of other exchanges and thereby effectively inhibiting
resource reuse.
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Other ideas were presented that, if implemented, would
provide an impetus to the development or expansion of waste
exchanges. One suggestion was to require the use of a broker,
a waste exchange, a recovery facility, or an in-house treat-
ment unit before a generator would be allowed to ship waste
to a disposer. It was pointed out that this presents some
obvious problems. Exchanges would also benefit from public
information programs concerning waste exchange and resource
reuse.
Specific benefits and barriers to cooperation among
exchanges were discussed and are presented in Table IV.l. The
requirement of manifesting hazardous waste before it can be
recycled was seen as a barrier, especially for waste oil.
If waste exchanges present a united front, they can more
effectively encourage waste exchange and resource reuse at
both state and federal levels. Through cooperation, waste
exchanges can launch a more effective public awareness
campaign, and they can also share technical, legal, and
environmental information that may be mutually beneficial.
Sharing of listings, particularly among non-profit exchanges,
appears to have few barriers, although a common coding
system needs to be developed and accepted, especially if
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computer data bases are used. Cooperation could be enhanced
between non-profit and for-profit exchanges by providing
for-profit exchanges with rewards for contributing to an
exchange initiated through a non-profit organization. This
arrangement would probably have to be worked out on a case
by case basis.
TABLE IV-1
BENEFITS AND BARRIERS TO COOPERATION
AMONG EXCHANGES
Benefits
1. Exchange of ideas for solving
common problems
2. Sharing of costs (e.g., for
advertising or public
announcements)
3. Increased exchange success rate
4. Increased probability of finding a
large volume of a particular
waste
5. More effective lobbying (at both
state and federal levels)
6. Increased public awareness
7. Environmental benefits
Barriers
1. Legal
disincentives
(liability)
2. Requirement of
manifesting
hazardous waste
3. Increased
operating costs of
exchanges
4. Costs of hauling
long distances
5. Possible breach of
confidentiality
6. Competition for a
finite amount of
funding
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V. RCRA REAUTHORIZATION AND NEW DEFINITIONS
CONCERNING RESOURCE REUSE»
EPA has been working over the past year to determine
what the agency's role should be in recycling and reuse of
waste. The major question is "how can EPA inhibit those types
of operations that should be inhibited while encouraging or at
least not discouraging legitimate recycling?" Under RCRA,
EPA has clear authority to regulate the recycling of hazardous
waste. Experience has shown important reasons to do so. For
example, a waste oil blender sold fuel containing PCBs and
chlorinated hydrocarbons to apartment houses in New York
City. Using contaminated waste oil as a dust suppressant has
all the same potential for harm as when this waste is land
disposed, as the state of Missouri has recently discovered.
Times Beach, Missouri, is only one of many such sites in the
state. The cost of purchasing homes in Times Beach alone is
$35 million. Of the 61 imminent hazard cases filed so far
under section 7003 of RCRA, one-third are recycling
operations. Twenty of the first 160 interim priority sites on
the Superfund list are also recycling operations. For example,
the Chemdyne facility in Hamilton, Ohio will cost $3.5
•This section is essentially a summary of the comments made
by Dr. John H. Skinner of U.S. EPA.
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million just to clean-up the surface. The groundwater costs
have not even been estimated. The Seymour site in Ohio will
cost at least $30 million to clean up. These were not sham
operations. The people were attempting to make money
recycling wastes and were using what they considered to be
good business practices. Many operations, however, went
bankrupt, leaving the cost of clean-up to someone else, EPA
is thus concerned about certain types of recycling operations.
The agency acknowledges that there are strong environ-
mental reasons to encourage the legitimate and beneficial uses
of hazardous waste. The act is after all called the "Resource
Conservation and Recovery Act," and certain types of mate-
rials are very analogous to industrial products and virgin
materials and should be treated as such. EPA is attempting to
put together a regulatory scheme that focuses on those
materials with potential for harm while exempting those for
which commercial or market incentives will in all likelihood be
sufficient to complete the recycling process.
In May 1980, EPA promulgated regulations on the reuse
and recycling of hazardous wastes. There are a number of
problems with these regulations. The regulations are very
broad. Some products should be regulated more and some
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should be regulated less. A proposal to amend these regula-
tions will appear in the Federal Register (48 CFR 14472; April
4, 1983; 120-day comment period to close August 2, 1983). A
free copy of the regulations may be obtained by calling the
EPA RCR A/Super fund hotline (800-424-9346; in Washington,
D.C. call 382-3000), and asking for the "redefinition of solid
waste as it pertains to recycling and reuse."
The new regulations define certain activities as solid
waste-related and then eventually as hazardous waste-related
based both on the material itself and how it is managed. Five
types of recycling activities currently are subject to regula-
tory control:
1. Placement of materials on land (use constituting
disposal).
2. Burning waste or waste-derived fuels for energy
recovery or using wastes to produce a fuel.
3. Accumulation of materials in a speculative matter
(that is, when there is no clear market).
4. Accumulation of materials without sufficient turn-
over. (Seventy-five percent of the material must
be recycled within one year or else the site must
be regulated as a storage facility.)
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5. Situations where reclamation occurs. In this
instance, materials are recovered from waste or
the waste itself is regenerated. This definition
brings into regulatory control certain products and
by-products. Regulation will apply only to listed
wastes and sludges.
There are several exemptions to the above, including:
1. Waste reclaimed by the generator and reused by
the generator.
2. Waste reclaimed and used by a reclaimer other
than the generator.
3. Specific exemptions, for example, precious metals
reclaiming and certain battery recycling activities.
Some materials are not considered solid waste in the
first place and are thus not subject to regulation. These
include:
a. Secondary materials used or reused as ingredients
or feedstocks in a production process, for example, fly ash in
manufacturing. These materials function as raw materials.
b. Secondary materials used as substitutes for raw
materials in recovery processes that normally use raw mate-
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rials as feedstocks. For example, use of secondary lead in a
primary lead smelter.
c. Secondary materials used or reused as substitutes
for commercial products.
d. Materials used in the same process that produced
them (closed loop process — same site, same process).
A waste exchange can exchange information without the
exchange being regulated. A recycler is also exempt from
regulation if he uses the material himself (see #2 above). The
recycler who processes material and then sells it is not
exempt. Listed wastes and sludges have to be manifested to
the recycler. If they are stored on-site, they are subject to
regulatory control. EPA's position is to support recycling, but
to make sure recycling actually occurs (i.e., to make sure the
waste is not left on site). Under RCRA in the hazardous waste
area EPA's major responsibility is as a regulatory agency. A
transfer site may collect waste, but the site would have to be
regulated as a storage facility. Likewise, incineration is
regulated but not prohibited. The question of whether an item
used both as a feedstock and as fuel is subject to regulation
was raised during discussion. The issue was not resolved. The
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actual burning of some waste is also exempted from regula-
tion, although EPA intends that this exemption be temporary.
Pending federal legislation may require the labeling of
all fuels that contain hazardous wastes. Since the legislation
has not passed, it is unclear whether this will require the
listing of specific components in a fuel. (Conference partici-
pants thought that such a requirement would inhibit the
recycling of oil, since large fuel blenders have hundreds of
sources, making identification of all components difficult, if
not impossible.) Waste oil itself is listed as a hazardous waste
in eight states. In other states, it is not subject to the new
regulations unless it has any of the four characteristics
(ignitability, corrosivity, reactivity, toxicity) or if a hazardous
waste is mixed into it. EPA is currently working on technical
standards for the burning and recycling of waste oil, which
should be available within the next 18 months. Waste oil will
also be listed as a hazardous waste.
It must be remembered that state regulations may
always be more stringent than federal regulations. For
example, in Massachusetts waste oil is already considered a
hazardous substance by the state.
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In 1983 a uniform national manifest form will be promul-
gated that preempts all state manifests. The form will go into
effect 180 days after promulgation. This will allow transport
of wastes across state lines without the need for separate
state manifests. However, the uniform manifest will not
affect specific requirements at either pick-up or delivery
points.
Under the new proposed definition of solid waste, EPA
estimates that 5,000 recycling operations will be subject to
less regulation at cost savings of $24 million. In many areas it
will be cheaper and easier to recycle; in some others it will be
more difficult.
In the discussion following the presentation, the spokes-
man for EPA indicated that he did not think the new regula-
tion will substantially affect waste exchanges. The com-
plexity of the regulations and the fact that they are still being
developed was viewed as an impediment by some conference
participants. EPA, however, believes that the changes in the
regulations are warranted and that once they are in place the
regulatory climate will become more predictable and effec-
tive.
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VI. INCENTIVES/BARRIERS TO SUCCESSFUL EXCHANGE
At present the barriers to successful exchange appear to
outweigh the incentives. There are several impediments to
exchange from the point of view of the generator. Many
generators do not realize what materials are suitable for
recycling nor do they know the pertinent regulations. They
may also be uncertain about whether a particular waste is
hazardous. Some generators fear that if their waste is
published on a waste exchange, their competitors will be able
to discover secrets of their production processes. Generators
also may not want to become involved in what they view as
"another business." Potential liability was identified
repeatedly as a barrier to generator participation in waste
exchanges. Cradle-to-grave generator liability makes genera-
tors hesitant about losing control of their hazardous waste:
they frequently prefer to manage it in a way which allows
them to feel they have more control over the waste's fate than
they would if the waste were reused. Generators also have a
potential storage problem. Under RCRA there is a 90-day
storage limit after which a permit to store waste is required.
EPA's proposed rule regarding the definition of "solid waste"
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discussed in Section V of these proceedings may change this
requirement. Listings in waste exchanges may not even be
published for 90 days. Storage of waste may also affect a
generator's insurance burden.
Unfavorable economics are another barrier to successful
exchange. Many wastes have a high volume but a low value,
making it cost-ineffective to transport them, particularly over
long distances. Transportation difficulties are compounded if
the wastes are hazardous and/or transported across state lines.
Companies involved in a waste transfer must pay other fixed
costs in addition to transportation costs. There are costs
related to price negotiations, material testing, and for any
equipment or process modifications needed to handle the
material. All these costs may be small on a per pound basis
when large amounts of material are exchanged regularly, but
the costs may become prohibitive when materials are available
one time only, irregularly, or in small amounts.
The fact that regulations are both complicated and
constantly changing, particularly with regard to the issue of
whether a substance is hazardous or not, is also a problem. It
was pointed out by one conference participant that both the
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stringency and complexity of regulations will affect the ex-
change.
Furthermore, there are technical impediments to the
recycling of certain materials. Even if the technology is
available, it may not be economical. An Argonne National
Laboratory publication entitled "Industrial Waste Exchange: A
Mechanism for Saving Energy and Money" (1982) points out
several areas where economical technology is needed: mate-
rials recovery from sludges, separation of close-boiling liquids,
and separation of mixed plastic or fiber wastes. Related to
this is the problem that, with the exception of technical
publications, no means exist for communicating new recycling
processes. Industrial processes change so rapidly that once a
successful exchange has been established between a generator
and a user, there is no way to guarantee that one side will
continue to produce and another continue to use a particular
material.
The passivity of most waste exchanges was also viewed
as an impediment to successful exchange. Most exchanges do
not actively market the waste. They do not take possession of
the material. Hence, their function as a intermediary is
limited.
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Other barriers to successful exchange were raised that
primarily affect recyclers rather than waste exchanges per se.
The public's attitude toward waste, particularly hazardous
waste, is negative. There is frequently local resistance to the
building of hazardous waste management sites. Defining a
material as a "waste" results in "spotlight" attention from
numerous public agencies. Handling of "hazardous waste" may
also result in problems with labor unions (for example, a
clean-up on a dock). The belief was expressed that complex
regulation can put excessive pressure on small businesses.
This was considered unfortunate because many of the small
firms are more efficient from a material transfer perspective
in that they deal with single types of wastes or small amounts
of waste. The most extreme consequences of excessive
regulation were considered to be bankruptcy of small firms,
unemployment, and shifting of the recycling field into the
realm of fewer large companies.
Recyclers as well as generators have serious liability
considerations. Preshipment sampling and analysis typically
are not adequate to insure the continued quality of the waste
received by recyclers. Obtaining a truly representative
sample, even for a single barrel, is not always possible. It was
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suggested that the recycler may specify parameters of what is
acceptable in a contract, but even if these parameters are not
met, it is not always possible to return the waste to the
generator. Waste cannot be returned to the generator unless
the generator is a licensed storage facility (EPA regulations,
40 CFR Part 262).
The incentives for successful exchange were also
discussed. One benefit is the amount of energy saved by using
existing rather than new materials. The Argonne report (p. 50)
states that the amount of energy saved by one waste exchange
over two and one-half years was 10 x 109 BTU. It is
calculated that a savings of 1012 BTU per year (the equivalent
of 100,000 barrels of oil) would result if 5Q exchanges five
times as large or as effective as that one existed. A
seemingly obvious incentive is the saving in cost over the cost
of disposal. Apparently, however, the cost of recycling is
often comparable to the cost of disposal, particularly for
hazardous waste. Currently there are taxes levied for produc-
ing hazardous wastes, but typically there are limitations on
tax incentives or advantages given to those who recycle
wastes. It was suggested that a tax incentive be given to
those who recycle and a liability fund be established. Money
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could be taken from the tax paid by waste generators and
diverted to waste exchanges or recyclers to partially cover the
regulatory burden.
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VII. STRATEGIES TO ENCOURAGE AND FACILITATE
WASTE EXCHANGE
This session focused on positive steps that may be taken
by waste exchanges, recyclers, and government to encourage
and facilitate waste exchange. Many laws have already been
passed to encourage recycling and resource reuse. For
example, RCRA has two basic purposes: (1) to protect human
health and the environment from hazardous and other solid
waste, and (2) to protect and preserve the natural environment
through resource conservation and recovery. Under RCRA,
states are also mandated to develop programs to assist in the
development of methods of disposal of solid waste that are
environmentally sound and that encourage the use of valuable
resources. The federal government, under RCRA, is required
to provide technical and financial assistance to the states and
to encourage cooperation among the various levels of govern-
ment and private industry. The view was expressed that in
spite of the requirements of RCRA, the federal government
has not encouraged resource recovery as fully as possible.
Many states have passed laws to encourage alternative
approaches to waste management. Some states also require
counties to establish their own resource recovery facilities.
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Most of these facilities are aimed at refuse incineration and
energy recovery. It was suggested that exchanges work with
the federal, state, and local governments and encourage the
development of programs that do, in fact, help to meet the
spirit of existing laws.
Several specific ways for government to encourage
waste exchange were suggested:
1. Educate generators about available options and
about liability issues. Generators need to be aware
of the economic and environmental advantages of
waste exchange and resource reuse.
2. Educate the public about the hazardous waste
problem.
3. Institute tax incentives to recycle waste materials.
4. Encourage the development of transfer stations.
5. Encourage members of industry to use existing
facilities and services. The policy in some states
of passing laws that go into effect several years in
the future in order to allow for the building of
necessary facilities was criticized. It was felt that
someone cannot be expected to invest in these
facilities before the market is there; on the
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contrary, it was felt that if one creates the market
the facilities will follow in normal course.
Waste exchanges and recyclers can also facilitate and
encourage waste exchange in the following ways:.
1. Promote industry use of waste exchanges through
seminars, trade shows, and direct mail advertising.
2. Encourage the development of new technologies to
solve waste disposal problems through resource
reuse, and encourage firms to utilize these
methods.
3. Offer generators financial incentives and contract
commitments to recycle waste materials.
4. Advertise exchange services in trade journals and
through public service announcements. Currently,
many exchanges do not extensively advertise their
services. Advertising is not as expensive as
commonly thought. For instance, an ad in the
magazine Chemical Purchasing reaches 38,000
people and costs $25. It also may be possible to
exchange ads with some magazines* Developing
the advertisement takes time, which was
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considered a problem for exchanges with limited
manpower.
5. Document and advertise successful exchanges.
6. Adopt a common listing format among exchanges.
7. Develop a means of quick response, including pro-
vision of a ready list of wastes available.
8. Educate the community. Point out that reusing
wastes is typically not more hazardous than the
material for which it is a substitute.
9. Encourage participation in waste exchange organi-
zations by public and private groups.
These steps may be taken by individual exchanges or they may
be taken collectively through, for example, a national associa-
tion for waste exchange.
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VIII. LEGAL CONSIDERATIONS AND LEGISLATIVE TRENDS
WITH REGARD TO WASTE EXCHANGE
There are legislative and legal incentives and disincen-
tives to waste exchange and recycling. In 1976 Congress
passed the Resource Conservation and Recovery Act (PL 94-
580, RCRA). The emphasis of the act—despite its title—has
not been on conservation or recovery of wastes. Certain
hazardous wastes are exempted from regulation under RCRA
when recycled, but some critics of the act believe more should
be done to encourage recycling of hazardous waste. Since the
passage of RCRA, several bills have been introduced to
encourage recycling through economic incentives. Two of
these bills would have promoted industrial recycling by means
of tax incentives. One bill provided tax advantages for
equipment that would reduce or eliminate waste; the other
provided tax advantages for energy recovery or savings involv-
ing industrial waste usage. None of the bills passed. Although
there are currently no federal tax incentives for recycling,
there is a federal tax levied on hazardous waste generated.
This tax serves as a modest incentive for recycling since waste
that is treated and rendered nonhazardous is exempted from
the tax.
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The federal regulations on the reuse and recycling of
hazardous wastes are being modified. The proposed changes
(detailed in Section V) will make it easier and less expensive to
recycle in some areas and more difficult in others.
States have also passed laws that affect recycling. The
trend at the state level has been to tax (through surcharges)
municipal solid waste as opposed to industrial waste. In some
states municipal resource recovery operations are exempt
from paying sales tax on resource recovery equipment.
Florida is considering expansion of this exemption to all
resource recovery operations. Some states have tax laws that
apply directly to recycling of industrial waste. In New Jersey,
for example, a tax advantage is given for waste that is
recycled. A tax is levied on generators of hazardous waste in
Florida and other states that is related to the cost of
disposing, treating, or storing of that waste. Waste that is
treated and rendered nonhazardous is exempted from the tax.
This provision was designed to encourage in-plant treatment of
wastes. Because this system relies on self-reporting, there are
probably many hazardous waste generators of which the state
is unaware and who are not paying the tax.
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Tax incentives remain controversial. The belief was
expressed that such incentives do not change the real cost of
waste treatment and disposal, but that they merely shift the
higher costs from one alternative to another. They may also
encourage more capital intensive operations and discourage in-
plant process modifications. Third, tax incentives may be
viewed by the private sector as providing inequitable advant-
ages to different firms.
Another legislative trend that may be an incentive for
recycling is the idea under consideration in California, i.e., the
banning of liquid wastes in landfills. In any case, the true
costs of landfill disposal may not be reflected by the actual
disposal costs, although in California the costs of liquids going
into landfills has recently doubled, creating a distinct disin-
centive. If these costs were more in line with actual costs,
generators would have more of an incentive for recycling. It
must be remembered, however, that recyclers have to bear
some increased costs of disposal themselves, since they also
produce waste that must be disposed of.
According to the March 9, 1983, State/Local Report
from the National Association of Recycling Industries, the
states have also begun to respond to EPA's new definition of
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solid waste and have begun to tighten their controls on
recycling. The Maryland Department of Health and the New
Jersey Department of Environmental Protection have proposed
that only materials recycled at the generator's own facility be
exempted from controls. In New York, the Department of
Environmental Conservation is attempting to have aluminum
dross listed as a hazardous waste even when it is recycled.
According to lawyers for the department, "industrial and
commercial by-products shipped for recycling should be
assumed to be a waste until the generator proves otherwise."
Similarly in Missouri a proposed rule classifies "by-products,"
as well as "spent materials" and "sludges," as wastes.
The field of hazardous waste has many legal concerns.
Possible legal problems are of concern to anyone in the chain
of custody of a hazardous material. The federal regulations
promulgated under RCRA do not establish legal liability.
Rather, they establish legal responsibility and delineate the
limits of legal liability (fines and imprisonment) that the
courts may impose. Generally, it is the courts that establish
the extent of liability. In recent court decisions, liability
under Superfund and RCRA has been construed as joint and
several. All responsible parties, including generators, trans*
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porters, disposers, and owners or operators of facilities, have
been brought in by the EPA and the Department of Justice to
bear the costs of clean-up and other relief. This trend has a
potential impact on waste exchanges, although brokers and
exchanges may not be liable if they keep waste out of their
legal possession. In the future there will probably be more
contractual agreements between generators or handlers and
people to whom they transfer the waste, and between genera-
tors and haulers or owners/operators of disposal sites. Super-
fund in particular makes provisions for indemnity clauses to be
entered into between parties, but these clauses do not insulate
a party from liability. The generator does retain the right to
indemnity from the person to whom the waste has been
transferred. In other words, the generator may sue the other
party if the contract is broken, but the generator may still be
held liable under joint and several liability.
For generators, the legal problem with waste exchanges
is that generators lose control of-the waste. Their continued
liability may influence a company's decision to become
involved in a waste exchange. The question was raised
concerning whether a waste generator who manifests wastes
to either a broker or recycler is liable for the segregated
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waste stream? The answer was a qualified yes. The gener-
ator's liability is not as severe if the material has been
altered. The thrust of liability under Super fund and KCRA is
on the hazardous waste component of the waste stream.
However, even waste that may seem "clean" today may cause
problems in the future.
Disposal, as well as recycling, may also cause legal
problems for generators. For example, if a generator ships his
waste to an approved disposal site and 15 years later the site
closes without complying with regulations for closing, the
generator may be held liable for his waste that leaks from the
site. However, if the site is closed in accordance with
regulations, liability is transferred under Superfund to a post-
closure liability trust fund.
In the Florida law, there is a liability "escape clause." If
a generator or transporter of hazardous waste complies with
the law and with the applicable rules and regulations promul-
gated under the law and contracts with a licensed hazardous
waste processing facility, then the generator or transporter is
relieved from liability for those wastes upon receipt of a
certificate of disposal from a licensed disposal facility.
Currently, there is no licensed disposal facility in Florida.
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This law has not been tested in the courts. Several cases cited
in the January/February 1983 issue of Hazardous Materials and
Waste Management suggest that generators may still be held
liable even if they comply with all the regulations.
Some recyclers expressed the concern that the quality of
the waste they receive frequently does not meet the para-
meters specified in the contract. Samples or test results
submitted for precontract review are usually the "cream" and
seldom reflect a true picture of the waste. For example,
several phases of a waste may exist in a single drum and
render representative testing nearly impossible. Suing the
generator for breach of contract or returning the waste were
not seen as feasible options. A clear answer, short of
extensive laboratory testing, was not decided upon.
Associated with the concern for product quality is the
uncertain credentials of various persons managing the waste.
Because of joint and several liability, generators and recyclers
must be concerned about the expedience and reliability of one
another. In addition, both the generator and the recycler
need to be concerned about the reliability of the transporter.
There are several means by which to check the credentials of
the other parties involved in an exchange of waste. Site visits
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are helpful, as is contacting firms who have done business with
the party in question. Compliance with applicable state and
federal regulations is another measure of reliability.
Concern was expressed that recycling was not a specific
option for managing waste from Superfund sites, although
opportunities clearly exist for some recycling activity. It was
suggested that individuals with this concern contact the EPA
regional office and that they also express their concern to
EPA's Office of Solid Waste and Emergency Response.
Several questions, prepared by panel members, were not
discussed because of time constraints. The questions are
listed below:
1. How does a generator check the reputation of a
company listed in an exchange catalogue?
2. Should a waste exchange catalogue specify liability
to generator/exchanger?
3. Will incentives/disincentives such as landfilling
bans or tax credits be necessary for waste ex-
change operations to continue?
4. What incentives can industry support which will
enhance their cooperation with waste exchanges
and the recycling effort?
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5. Should a state agency be able to request a list of
all firms that asked to be put in contact with a
receiving firm if the receiving firm becomes in-
volved in an enforcement/clean-up action?
6. Should waste exchanges that deal in actual mate-
rial (i.e., materials exchanges) be required to
notify the state (or EPA) and be subject to permit
(storage) requirements? Current federal regula-
tions require material exchanges (as storage facili-
ties) to notify EPA and obtain a storage permit.
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IX. NEED FOR A NATIONAL ASSOCIATION FOR
WASTE EXCHANGE AND RESOURCE REUSE
Advantages of a national association were discussed in a
preliminary session on the first day of the conference. These
included facilitation of communication among members,
lobbying at state and federal levels, documentation or licens-
ing of members as legitimate operators, and dissemination of
technical, legal, financial, and environmental information on
recycling. A national waste exchange listing wastes from
throughout the United States may not be reasonable or work-
able, but a trade association which represents exchanges
could be a useful entity.
The National Association of Solvent Recyclers was
described as a model of a national trade association. Trade
associations have more effective input into the political
process than individuals. For example, the National Associa-
tion of Solvent Recyclers met with EPA officials concerning
the recent redefinition of solid waste. Government officials
frequently do not have the time to meet with as many
individuals as they would like, but individuals can have their
voice heard through trade associations. Lobbying may be
achieved, for example, through the use of existing manage-
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ment firms specializing in this area. This could be less
expensive than establishing a separate office, and members of
an existing firm may already have established personal
contacts with government officials and members of Congress
interested in recycling and resource reuse. The National
Association of Solvent Recyclers pays for the services of a
professional management association through dues charged to
members.
Associations may provide many useful functions. For
example, meetings sponsored by associations can lead to
communication among participants that are frequently more
effective than computer exchanges. Trade associations can
also provide a list of certified labs, consolidate programs, and
serve as a clearinghouse for technical information. A trade
association could also disseminate information on, for
example, relevant legislation or technical innovations, through
a newsletter. It was suggested that the association consider
publishing a technical magazine devoted to resource reuse.
Current magazines focus on recycling specific materials
through existing scrap markets (for example, paper, glass,
metals). An association may regulate its members through a
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code of ethics and help to maintain the relatively positive
image waste exchanges have currently.
Several tasks must be accomplished before such an
association can be established. The scope, purpose, and
function of the association must be determined. It was
suggested that the goal of such an association be to facilitate
waste exchange, not waste exchanges. Next, it must be
decided what groups will be included in the association.
Should all the types of people represented at the confer-
ence—generators, brokers, recyclers, consultants,
regulators—be included or should only those people who
engage in waste exchange under a particular definition be
included? The consensus seemed to be that initially the
membership of the association should be broadly defined to
include all groups and that the association develop a code of
ethics. It was also suggested that the association include
members from outside the United States as well.
The second day's session on the establishment of a
national association began with the exchange of ideas not
directly linked to the session topic. A recent technological
development (ground penetrating radar) can be used to detect
subsurface drums. One participant reaffirmed the need for
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highly qualified middlemen to get generators and recyclers
together. These middlemen should have access to the
recycler's financial records and EPA records, as well as
knowledge of the specific recycling process. Because of
"cradle-to-grave" liability for hazardous waste, a company
would be unwise to part with its waste without this kind of
information.
The issue of environmental audits to identify potentially
recyclable wastes for a company was also raised. Waste audits
are particularly useful to small companies and could be
performed under the auspices of the association. For example,
in Leon County, Florida, a hazardous waste assessment
revealed that rfiany small quantity generators did not know
they were generating hazardous waste. They were also
unaware of the options available to them in addition to
traditional management methods. The point was made that it
is important to involve local governments as well as federal
and state governments in the hazardous waste management
process.
A resolution was made to form a national association
"for waste exchange and resource reuse." The association's
initial goal, as a follow-up forum to this conference, would be
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to draft a position paper based on the discussion from the
conference. The position paper would be sent to all partici-
pants for review and then redrafted.
Representatives from several waste exchanges met in-
formally and agreed to exchange catalogs, investigate the
standardization of waste categories, and work toward a
universal coding scheme that would maintain user confiden-
tiality while providing consistency in listing information.
The session ended with the agreement that Dr. Roy C.
Herndon would organize a committee to prepare a position
paper to define tasks that need to be accomplished. The
position paper should identify the need for and functions of the
association. After these are specified, other aspects of the
association such as structure, by-laws, membership require-
ments, and code of ethics may be proposed.
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APPENDIX A
CONFERENCE AGENDA
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National Conference on Waste Exchange
P.O. Box 6467
Tallahassee, Florida 32313
(904) 644 2007
Florida State Conference Center West Pensacola and Copeland
MARCH 8-9, 1983
A Conference to Encourage Resource Reuse
Through Waste Exchange and Recycling
AGENDA
Monday Evening, March 7
7:00 Pre-Conferenee Hospitality Hour and Early Registration
Salon A-Bf Hilton Hotel
101 South Adams Street
Tuesday Morning, March 8
8:00 REGISTRATION AND CONTINENTAL BREAKFAST
Florida State Conference Center
West Pensacola and Copeland
9:00 INTRODUCTION AND ANNOUNCEMENTS
Conference Coordinator: Roy C. Herndon, Florida State University
9:15 CONFERENCE OVERVIEW
o Review of Waste Exchange Activities
o Objectives and Goals of the Conference
o Program Format
John E. Moerltns: Waste Management Program, Florida State
University
9:30 SESSION I - Waste Materials Suitable for Exchange
o Examples of Recyclable Waste Streams
o Potentially Valuable Waste Streams
o Process Modifications to Enhance Transferability of Wastes
Moderator: Richard L. Floyd, Union Carbide Corporation
10:00 BREAK
THE
FLORIDA .
CHAMBER
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10:15 SESSION H - Expectations of Industry and Commerce In Waste
Exchange Activity
• Services Provided by a Waste Exchange
• Maintaining Confidentiality
• Cost Effectiveness of Waste Exchange Operations
• Evaluating Liability
Moderator: Christopher Teaf, Southern Waste Information Exchange
Panel: Jack HoUingsworth, M.J. Hollingsworth and Company
John Miller, Standard Oil Company (Indiana)
Charles Littlejohn, Florida Chamber of Commerce
11:00 SESSION m - Cooperation Among Exchanges: The Key to Effective
Service to UJS. Industry
• Feasibility and Mutual Benefits of Cooperation among
Exchanges
• Barriers to Cooperation among Exchanges
• Mechanisms for Cooperative Exchange of Information
• Examples of Cooperative Activity among Exchanges
Moderator: Elizabeth Dorn, Piedmont Waste Exchange
11:45 SESSION IV - RCRA Reauthorization and New Definitions Concerning
Resource Reuse
John H. Skinner
Office of Solid Waste
U.S. Environmental Protection Agency
12:15 BUFFET LUNCHEON
Florida State Conference Center
West Pensacola and Copeland
Topic: Session Summaries, Discussion and Follow-up Tasks
Moderator: John E. Moerllns, Florida State University
Panel: Elizabeth Dorn, Piedmont Waste Exchange
R.L. Floyd, Union Carbide Corporation
Christopher Teaf, Southern Waste Information Exchange
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Tuesday Afternoon, Mtrvh 8
1:30 SESSION V - Incentives/Barriers to Successful Exchange
• Conceptual
• Economic
• Legal
• Regulatory
Co-Moderators: Linda Gaines, Argonne National Laboratory
Trevor Pitts, Zero Waste Systems
2:30 BREAK
2:45 SESSION VI - Preliminary Discussion Concerning Need tor a National
Association for Waste Exchange
• Purpose
• Anticipated Structure and Functions
• Developmental Strategies
• Cooperative Activities, Regionalization
Co-Moderators: Leslie Allen, Allworth Inc.
Walker Banning, Northeast Industrial Waste
Exchange
3:45 BREAK
4:00 SESSION SUMMARIES, DBCUBSKM AND FOLLOW-UP TASKS
Moderator: Roy C, Herndon, Conference Coordinator
Panel: Leslie Allen, Allworth Inc.
Walker Banning, Northeast Industrial Waste Exchange
Linda Gaines, Argonne National Laboratory
Trevor Pitts, Zero Waste Systems
5:00 ADJOURN
Tuuday Evening, Mmxh 8
7:00 DINNER PROGRAM
The Florida Room
Hilton Hotel
e Critique of Day's Activities
e Setting the Stage for Tomorrow's Sessions
Edward A. FernaId, Roy C. Herndon; Florida State University
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Wednesday Morning, March 9
8:00 REGISTRATION AND CONTINENTAL BREAKFAST
Florida State Conference Center
West Pensacola and Copeland
9:00 PANEL SESSION I - Legal Considerations and Legislative Trends
• Liability of a Generator Following Waste Transfer
• State Regulatory Positions Concerning Waste Exchange
• Status of Federal Legislation/Regulation Concerning Waste
Exchange
Moderator: Rolf P. Hill, U.S. Environmental Protection Agency
Panel: Raoul Clarke, Florida Department of Environmental
Regulation
William Preston; Hopping, Boyd, Green and Sams
Lori Spencer, Spencer Environmental Consultants
9:40 PANEL SESSION n - Strategies to Encourage and Facilitate Waste
Exchange
Moderator: Marcel Veronneau, Environmental Waste Removal, Inc.
Panel: Bob ArundtAe, III, BCR Inc.
Robert O. Ktncart, Resource Recovery of America
Donna Trask, New England Materials Exchange
Anthony Tripi, I.C.M. Chemical Corporation
10:20 BREAK
10:30 PANEL SESSION m - Structure and Function of a National Association
for Waste Exchange
• Proposed Structure and Administration
• Long-term Goals and Activities
• Follow-up Strategies and Responsibilities
Moderator: Roy C. Herndon, Conference Coordinator
Panel: Walker Banning, Northeast Industrial Waste Exchange
Julia I. Barrow, Industrial material Exchange
Thomas Herbert, T.A. Herbert and Associates
William Stough, Waste Systems Institute
11:30 CONFERENCE SUMMARY AND CRITIQUE
• Summary of Conference
• Strategies to Implement Ongoing Activities
• Future Meetings
12:00 CONFERENCE ADJOURNMENT
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APPENDIX B
CONFERENCE PARTICIPANTS
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CONFERENCE PARTICIPANTS
NATIONAL CONFERENCE ON WASTE EXCHANGE
March 8-9, 1983
Ms. Judith Abernathy
Director of Membership Development
Tennessee Manufacturers Association
501 Union Bldg., Suite 601
Nashville, Tennessee 37219
Mr. Jack Adams
Energy Recovery Group
6301 North Federal Highway
Boca Raton, Florida 33432
Ms. Dorothy Adams
Energy Recovery Group
6301 North Federal Highway
Boca Raton, Florida 33432
Mr. Leslie S. Allen, President
Allworth, Inc.
500 Medco Rd.
Birmingham, Alabama 35217
Mr. Jimmie W. Anderson
Martin Marietta Aerospace
P.O. Box 29304
New Orleans, Louisiana 70189
Mr. Scott Andree
Florida Sea Grant
P.O. Box 820
Perry, Florida 32347
Mr. Robert Arner
Association of Government Oil Recycling Officials
P.O. Box 1719
Sebring, Florida 33870
Mr. Bob Arundale, III, President
B.C.R., Inc.
1281 N. Farnsworth
Aurora, Illinois 60505
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Mr. Walker Banning, Manager
Northeast Industrial Waste Exchange
700 East Water St., Room 711
Syracuse, New York 13210
Ms. Julia I. Barrow
Illinois EPA
2206 Churchill Rd.
Industrial Material Exchange
Springfield, Illinois 62706
Mr. Clyde S. Brooks
Recycle Metals
41 Baldwin Lane
Glastonbury, Connecticut 06033
Mr. L. Raoul Clarke
Environmental Specialist-Hazardous Waste
Florida Department of Environmental Regulation
2600 Blair Stone Rd.
Tallahassee, Florida 32301
Mr. Eugene N. Collins
City Attorney
400 Pioneer Bank Building
Chattanooga, Tennessee 37402
Mr. Bruce Cranford, Jr., P.E.
U.S. Department of Energy
Office of Industrial Programs
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Mr. David Creech
Magnum International
P.O. Box 518
Glenwood, Illinois 60425
Mr. Mike Creech, President
Abraxys, Inc.
P.O. Box 33
Sterger, Illinois 60475
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Mr. George L Davis
Davis Refining Corporation
P.O. Box 6089
Tallahassee, Florida 32301
Mr. Don F. Dicus
Bryson
108 White Oak Lane
Lexington, South Carolina 29072
Ms. Elizabeth W. Dorn, Director
Piedmont Waste Exchange
UNCC Station
Charlotte, North Carolina 28223
Ms. Kathleen Durrell
Environmental Specialist
Tampa Electric Company
P.O. Box 11
Tampa, Florida 33601
Dr. Edward A. Fernald
Assistant Vice President for Academic Affairs
361 Bellamy Building
Florida State University
Tallahassee, FL 32306
Mr. John Fletcher
Goodwill Industries
Tampa, Florida
Mr. Richard L. Floyd
Union Carbide Corporation
P.O. Box 8361, Bldg. 3005/3
South Charleston, West Virginia 25303
Lt. Col. Jimmy N. Fulford
HQ AFESC/RDVA
Tyndall Air Force Base, Florida 32403
Dr. Linda Gaines
Argonne National Laboratory
9700 South Cass Avenue
Argonne, Illinois 60439
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Ms. Marilyn O. Godwin
Pensacola-Escambia Clean Community Commission
402 S. Jefferson St., Suite 100
Pensacola, Florida 32501
Ms. Sandra Goodrich
Department of Environmental Quality Engineering
One Winter St., 8th Floor
Boston, Massachusetts 02108
Mr. John J. Hartley, President
Southern Solvents, Inc.
P.O. Box 271251
Tampa, Florida 33688
Dr. Thomas A. Herbert
T.A. Herbert and Associates
P.O. Box 10129
Tallahassee, Florida 32302
Dr. Roy C. Herndon
Director of Research
Institute of Science and Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, Florida 32306
Mr. Edward V. Hickey
Westinghouse Electric Corporation
1801 K. St., N.W.
Washington, D.C. 20006
Mr. Rolf P. Hill, Environmental Engineer
U.S. EPA (WH-563)
Office of Solid Waste
401 M. St., S.W.
Washington, D.C. 20460
Mr. Jack Hollingsworth
M.J. Hollingsworth and Company
4 Park Office Circle
Birmingham, Alabama 35217
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Mr. John H. Holmes, Jr.
JBC Company
P.O. Box 6425
Ft. Myers, Florida 33906
Mr. Wayne M. Hosid, Environmental Specialist
Florida Department of Environmental Regulation
160 Government Center
Pensacola, Florida 32501
Ms. Patricia L. Jerman, Director
Division of Natural Resources
P.O. Box 11450
Columbia, South Carolina 29211
Mr. Robert O. Kincart
Resource Recovery of America, Inc.
2300 Highway 60 West
Mulberry, Florida 33860
Mr. Chester Klinger
Manufacturing Engineer
Sperry Corporation
P.O. Box 4648
Clearwater, Florida 33518
Mr. Raymond P. Krebs
The Ryda Corporation
3105 Wengate Drive
Marietta, Georgia 30062
Ms. Linda L. Lampl
T.A. Herbert and Associates
P.O. Box 10129
Tallahassee, Florida 32302
Mr. R.G.W. Laughlin
Ontario Research Foundation
Sheridan Park Research Community
Mississauga, Ontario CANADA L5K 1B3
Mr. Charles Littlejohn
Florida Chamber of Commerce
P.O. Box 11309
Tallahassee, Florida 32302
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Mr. George Marcou
Westinghouse
1801 K. St. NW
Washington, D.C. 20007
Mr. James McBain, Executive Director
Association of Petroleum Rerefiners
2025 Pennsylvania Avenue, Suite 1111
Washington, D.C. 20006
Ms. Mary McDaniel, Associate Director
Piedmont Waste Exchange
UNCC Station
Charlotte, North Carolina 28223
Mr. Robert McVety
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
Mr. John A. Miller
Environmental Technologist
Standard Oil Company (Indiana)
200 E. Randolph Drive
Chicago, Illinois 60601
Mr. John E. Moerlins
Research Economist
Institute of Science and Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, Florida 32306
Mr. Raymond Moreau
Resource Recovery Section
Florida Department of Environmental Regulation
2600 Blair Stone Rd.
Tallahassee, FL 32301
Mr. W.R. Murphy, Hydrologist
P.E. LaMoreaux and Associates
4313 South Florida Avenue
Lakeland, Florida 33803
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Mr. Wayne H. Owens, Planning Projects Coordinator
Container Corporation of America
North 8th St.
Fernandina Beach, Florida 32034
Mr. Steven Paikowsky
Legislative Analyst
House Community Affairs Committee
House Office Building
Tallahassee, Florida 32301
Mr. John R. Peoples
Chemical Waste Management, Inc.
2110 Newmarket Parkway, Suite 111
P.O. Box 3065
Marietta, Georgia 30067
Mr. Trevor Pitts
Zero Waste Systems, Inc.
2928 Poplar St.
Oakland, California 94608
Mr. Richard Powell
Florida Department of Environmental Regulation
7601 Highway 301 N.
Tampa District Office
Tampa, Florida 33610
Mr. William Preston, Esq,
Hopping, Boyd, Green and Sams, P.A.
Lewis State Bank Building
Tallahassee, Florida 32301
Dr. Elizabeth D. Purdum
Publication Director
Institute of Science and Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, FL 32306
Mr. Martin A. Rowland
Martin Marietta
P.O. Box 29304
New Orleans, Louisiana 70189
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Ms. Suzi Ruhl
Legal Environmental Assistance Foundation
2330 Highland Avenue, South
Birmingham, Alabama 35205
Ms. Susan Santos
U.S. Environmental Protection Agency
J.F. Kennedy Building, 19th Floor
Boston, Massachusetts 02203
Mr. Wade Schroeder
735 8th St. South
City of Naples
Naples, Florida 33940
Mr. Mark Shaw, Operations Manager
PV Technologies
P.O. Box 83
Ortega Station
Jacksonville, Florida 32210
Dr. John H. Skinner, Director
Office of Solid Waste (WH-562)
U.S. EPA
401 M. Street, S.W.
Washington, D.C. 20460
Mr. Sam Sloan
Solid Waste Program Specialist
Bureau of Solid Waste Management
P.O. Box 2063
Harrisburg, Pennsylvania 17120
Mr. William M. Sloan, Secretary
Maryland Hazardous Waste Facilities Siting Board
60 West St., Suite 200
Annapolis, Maryland 21401
Mr. Frank Smith, Director
Solid Waste Facility
Leon County Public Works Department
Tallahassee, Florida 32301
Ms. Lori P. Spencer, President
Spencer Environmental Consultants, Inc.
2313 Old Columbiana Rd.
Birmingham, Alabama 35216
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Ms. Nancy Stephens
Legislative Analyst
Senate Natural Resources Committee
416 Senate Office Building
Tallahassee, Florida 32301
Mr. William A. Stough
Great Lakes Regional Waste Exchange
Waste Sytems Institute
3250 Townsend N.E.
Grand Rapids, Michigan 49505
Mr. Christopher M. Teaf
Associate Director
Southern Waste Information Exchange
P.O. Box 6487
Tallahassee, Florida 32313
Mr. Eugene Theios, Manager
Disposal Alternatives Unit
Illinois Environmental Protection Agency
2200 Churchill Rd.
Springfield, Illinois 62706
Ms. Donna L. Trask, Director
New England Materials Exchange
P.O. Box 947
Kennebunk, Maine 04043
Mr. Anthony L. Tripi, President
ICM Chemical Corporation
8282 Western Way Circle, Suite 205
Jacksonville, Florida 32216
Mr. Hartsill Truesdale
Office of Solid Waste
Department of Health and Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
Mr. Marcel Veronneau, President
Environmental Waste Removal, Inc.
130 Freight St.
Waterbury, Connecticut 06702
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Ms. Patricia Vindett, Vice President
Hazardous Waste Consultants
2800 W. SR 434, Suite 1297
Longwood, Florida 32750
Mr. Johnny Williams
Escambia County Solid Waste
Rt. 4, P.O. Box 110
Cantonment, Florida 32533
Ms. Geraldine Wyer
Office of Solid Waste
U.S. EPA
401 M. St. SW
Washington, D.C. 20460
Ms. Rose A. Zongker
Administration Liaison
National Conference on Waste Exchange
P.O. Box 6487
Tallahassee, Florida 32313
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