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Article # 0057


Unique Hazardous Waste Issues Facing Fiberglass Manufacturers in Texas


(Note:  Information in this discussion is based on federal hazardous waste regulations in 40 CFR 265 and Texas regulations found in 30 TAC Chapter 335.)


In the fiberglass manufacturing industry, there are generally two unique sources of hazardous waste.


  1. Spent acetone from resin and gelcoat clean-up.  This acetone waste also contains waste resin and gelcoat from raw materials described in the next category.


  1. Waste resin and gelcoat from raw materials that can no longer be used in production.  These materials will generally be in the drums or totes that they were received in at the plant.  Small amounts are also generated during production activities in buckets or other small containers where unused raw materials polymerize without being utilized for manufacturing purposes.  It is extremely uncommon for these materials received in bulk storage tanks to become unusable (i.e. to become wastes).  As mentioned above, this waste is also present as a sludge in the spent acetone that has been used for cleaning purposes.


Federal and state (Texas) waste definitions specify that a material becomes a waste as soon as it can no longer be utilized in the manufacturing process. For acetone, the spent material is a waste as soon as it is collected after clean-up of resin and/or gelcoat.  The resin/gelcoat sludge becomes a waste as soon as it is cleaned off the equipment and resin/gelcoat that is polymerized in small buckets/containers becomes a waste when it can no longer be used in production.  It is a little more difficult to determine when resin/gelcoat raw materials in their original containers become waste but, in general, they should be considered waste once it is known that the material is unusable.


In the past, some fiberglass manufacturers have desired to handle the acetone waste by allowing it to evaporate.  The dry sludge of waste resin/gelcoat would then polymerize and become a nonhazardous material that can be disposed of as a Class II waste.


Spreading the acetone out to dry and letting the sludge polymerize is technically defined as waste treatment, which requires a permit.  However, facilities can be exempt from permitting if they conduct waste treatment in a totally enclosed vessel. The way that fiberglass manufacturers often comply with this requirement is to use an acetone still to recover usable, clean acetone. Then, the sludge naturally polymerizes in the still bottoms as part of the recycling process.  The container is technically considered enclosed as well. 


Any unpolymerized bottoms or waste resin/gelcoat is polymerized in closed drums to meet the total enclosure requirement. Since pressure relief is needed during the polymerization, a spring-loaded pressure relief valve may be placed in the drum bung-hole. This minimizes the amount of styrene emitted to the atmosphere during polymerization. The process described here is known and approved of by the EPA and the Texas Commission on Environmental Quality as the POLYM treatment standard for composite manufacturers.  EPA’s POLYM treatment standard allows polymerization of waste resin to render it nonhazardous and discusses the conditions under which the treatment can occur without a permit. See link to Federal Register/Vol. 62, No. 91 at http://www.gpo.gov/fdsys/pkg/FR-1997-05-12/pdf/97-11636.pdf  The POLYM standard begins at part D. on page 26007.


When a facility describes their waste treatment in this manner, the following waste streams and waste management units are needed on the Notice of Registration:


For the annual waste summary report, the amount of acetone recycled must be reported as a recycled hazardous waste and the recycling activity must be shown on the NOR.  The amount of resin/gelcoat waste polymerized must be estimated and reported.



A less common scenario might involve the polymerization of the waste resin inside an enclosed building to meet the requirement of total enclosure.  This scenario is treated as an FAQ below.


FAQ on Treatment of Scrap Resin in a Containment Building


(Note: these answers are based on the federal and state regulations mentioned, as well as responses from TCEQ staff to the questions shown below.)


I have some questions about the treatment of scrap resin.  The scenario I have in mind involves treatment of scrap resin under the EPA's POLYM treatment standard.  I know that treatment in drums is allowed under conditions meeting 40 CFR 265 Subpart CC without a permit as long as the hazardous material is kept on site less than 90 days.  My questions pertain to the same treatment occurring in a containment building.


Question 1 - Can the same sort of treatment (i.e. no permit required if hazardous material is on site less than 90 days) occur in open containers in a building that is vented with a carbon canister to control emissions if the emissions are authorized under 30 TAC 116 or 106?  The question is really asking whether this type of building would be considered a "containment building under 40 CFR 265 Subpart DD. 


Answer 1 -  As long as the containment building meets the standards outlined in 40 Code of Federal Regulations (CFR) § 262.34 (a)(iv), a facility can treat their hazardous waste without a permit during the 90 day accumulation time. The standards for containment buildings are outlined in 40 CFR Chapter 265 Subpart DD.



Question 2 - Is the building enclosed for the purposes of this regulation? 


Answer 2 - 40 CFR § 265.1101 (a)(1) outlines the requirements for a containment building being enclosed: “The containment building must be completely enclosed with a floor, walls, and a roof to prevent exposure to the elements, (e.g., precipitation, wind, run-on), and to assure containment of managed wastes.”



Question 3 - Is there any way to accomplish treatment in a building of this sort without getting a waste permit?


Answer 3 - The containment building must meet the above standards and the treatment must be done during the generator's 90 day accumulation time to be exempt from permitting requirements.



Question 4 - Also, regarding both treatment in enclosed containers and in a containment building, do you count the period of time the treated material remains on site after it has been rendered non-hazardous toward the 90 day period that hazardous waste can be on site without requiring a permit? Or, does the clock stop when the material is no longer hazardous?


Answer 4 - After the waste has been treated, a new waste is generated.  If that waste is nonhazardous, then the 90 day accumulation time limit no longer applies.



Karen M. Bullard, P.E. is an Engineering Partner and the President of Bullard Environmental Consulting, Inc.   She has over 16 years experience in environmental engineering, compliance, and permitting.  She worked for the Texas Commission on Environmental Quality (TCEQ) for four years as an Air Permit Specialist in the Coatings and Combustion Section, where she developed a thorough understanding of the governmental procedures and policies in Texas.    Karen has a Bachelors of Science Degree in Chemical Engineering from the University of Texas at Austin.


Karen M. Bullard, P.E. No. 88449


Article # 0057

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