United States                 Solid Waste and           EPA530-F-02-015
                Environmental Protection Agency    Emergency Response          February 2002
                                         (5305W)              http://www.epa.gov

                Office of Solid Waste
  SERA   Environmental
                 Fact  Sheet
                EPA Proposing to Allow Waste as an
                Energy Source for Synthesis  Gas
                Production and  Power Generation

                EPA is Proposing to Conditionally Exclude, From RCRA's Definition
                of Solid Waste, Hazardous Secondary Materials That are Processed
                in Gasification Systems to Manufacture Synthesis Gas
For the last 40 years, gasification technologies have been used commercially for the production of fuels
and chemicals. Modern gasification systems are designed to convert carbon-containing materials into a
synthesis gas product that can be used for energy production or as a building block for other chemical
manufacturing processes. Coal, petroleum coke, hazardous oil-bearing secondary materials from the
refining industry, municipal sewage sludge, hydrocarbon contaminated soils, and chlorinated hydrocarbon
by-products have all be used successfully in gasification operations.

EPA believes that gasification systems processing hazardous secondary materials are better viewed as a
production or manufacturing operation rather than a hazardous waste management activity. To that end,
EPA proposes that RCRA requirements that attach to these operations present an unnecessary
impediment to a legitimate fuel manufacturing activity.

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

 !  Increased resource conservation through displacement of virgin materials used in manufacturing; and

 !  Reduction in energy usage and pollution from reductions in the acquisition, transportation, and
   preparation of virgin materials used in electricity production, petroleum refining, and chemical
   manufacturing industries.

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

 !  System meets the definition of a gasification system;
 !  System generates a synthesis gas fuel meeting the specifications of exempted synthesis gas;
 !  Materials generated by the gasification system are not placed on the land if they exceed
   nonwastewater Universal Treatment Standard (UTS) for chromium, lead, nickel, vanadium, arsenic,
   and antimony shown in the 40 CFR 268.48; and
 !  Materials are not placed on the land or speculatively accumulated prior to their insertion into the
   gasification system.

EPA is also proposing an expansion of this conditional exclusion to other hazardous secondary materials
from other industrial sectors. To expand the exclusion, three modifications are proposed:

 !  Nonwastewater UTS constituents would increase from six to fifteen - capturing the entire suite of
   inorganic constituents regulated by RCRA in 40 CFR 268.48.
 !  Each hazardous secondary material processed in a gasification system has a total organic carbon
   (TOC) content of at least 20%; and
 !  Mercury-bearing secondary materials wastes can not be processed in the gasification system.
For More Information
The Federal Register Notice, this fact sheet and related documents are available in
electronic format at: .  For
additional information, or to order paper copies of any documents, call the RCRA Call
Center. Callers within the Washington Metropolitan Area please dial 703-412-9810 or
TDD 703-412-3323 (hearing impaired). Long-distance caUers please caU 1-800-424-
9346 or TDD 1-800-553-7672. The RCRA Call Center operates weekdays, 9:00 a.m. to
5:00 p.m. Address written requests to: RCRA-Docket@epa.gov or RCRA Information
Center (5305W), 1200 Pennsylvania Avenue, NW, Washington, DC 20460-0001.