Advanced Recycling of Plastic – An Overview with Lessons from Other States
Advanced Recycling (AR), also called Chemical or Molecular Recycling, is an industrial process using chemicals and/or extreme heat (pyrolysis) to convert many kinds of plastic waste to fuel, plastic building blocks, or other chemicals. Operation details are not well known due to industrial secrecy laws. In contrast, more traditional mechanical recyclers use only a few types of plastic to shred and reshape into selected products.
Advanced Recycling – Coming Soon to our State?
AR facilities are appearing across the U.S., and the Granite State looks more attractive than other states due to a 2022 New Hampshire (NH) law that classified AR facilities as manufacturing rather than solid waste plants. [i] Unlike manufacturing, a waste facility, to be permitted, must demonstrate “a substantial public benefit,” economic viability, and meet other criteria. [ii] NH is the only state in New England designating AR as a manufacturing process. However, since 2017, 21 other states have adopted similar laws through lobbying efforts of the American Chemistry Council, a trade group of plastic manufacturers and fossil fuel companies including Exxon, Shell, Chevron and others. [iii]
NH's AR law focuses on facilities planning to sell products from plastic waste for uses other than fuel, unlike some state laws that include plastic-to-fuel operations. In most facilities, however, breaking down plastic produces substances useful as fuel, and the NH law specifically allows operators to burn fuel made from plastic waste inside the facility itself. [iv] NH already has a plastic-to-fuel facility in Groveton that, after several years, remains in a test phase.
NH laws for air emissions apply to all facilities, with specific regulations to limit and monitor emissions depending on expected emission amounts and substances. Unexpected emissions sometimes occur, with serious consequences. The plastic coating facility, Saint Gobain in Merrimack released unregulated amounts of PFAS for decades, contaminating the Merrimack River and water wells with this persistent chemical. In 2020 the DES issued a new permit to reduce Saint Gobain’s allowed PFAS releases.
This and other PFAS cases illustrate the chronic problem that laws to control pollutants often lag behind the pace of production of new – or newly identified – hazards. NH and other states would benefit from a practical idea used elsewhere - the precautionary principle. Simply put, each new chemical or process is viewed as potentially harmful, and rigorous independent proof is required well before any public exposure. In NH and the U.S., regulations are not as precautionary, and municipal leaders are wise to be cautious about new industries.
Examples of Advanced Recycling in Other States
In viewing potential risks and benefits from an AR facility, municipal leaders need specifics. Local leaders might be tempted to view a proposed AR facility as a way to gain property tax revenue, redirect waste, or cut the solid waste budget, but leaders need to see the whole picture. Real world examples of AR in other states can help local decision makers judge the full impact of an AR facility in their community.
(Figure 1: Hazardous smoke from fires at a plastic storage facility in Richmond, Indiana)
First, AR does not cut waste collection costs. AR facilities depend on municipalities shouldering that burden. [v]
Second, AR facilities require large amounts of plastic waste. This usually arrives via trucks, e.g., dozens to over 50 deliveries per day, and the waste is often stockpiled, creating a fire hazard. As a fossil fuel derivative, plastic can produce extended fires. Also, burning many plastics produces harmful toxics, including dioxin, a persistent carcinogen carried in smoke. The days-long fire of a plastic waste storage facility in Richmond, Indiana is an example from this year, [vi] and, in 2021 a plastic-to-fuel facility in Ashley, Indiana burned for hours involving a mix of plastic feedstock and fuels in production. [vii] (Figure 1).
Third, conversions of plastic waste to other products release harmful air pollutants including the following: carcinogens such as dioxin, benzene and formaldehyde; Volatile Organic Compounds (VOC) and ozone triggered by VOC that are respiration hazards; and endocrine disruptor VOCs such as polycyclic aromatic hydrocarbons that mimic hormones like estrogen. Of note, permitted VOC emissions from AR in Ohio and Indiana are 10 to over 100 times greater than VOCs from incinerators in Indiana and New Hampshire. [viii] (Figure 2). Regarding one of the more harmful VOCs, benzene, the AR facility in Indiana can release annually up to 12,840 pounds of benzene while, in contrast, a gasoline station releases about 33 pounds of benzene per year. People living near a cluster of gas stations have a significantly higher cancer risk from benzene. [ix]
Fourth, solid waste and also some air emissions contain other persistent toxics present in plastic products, including heavy metals such as lead and organics such as PFAS. Problems with these substances are, unfortunately, too well known in the Granite State. AR facilities in states with strict rules for solid waste handling are now sending their waste to less stringent states where the waste is incinerated or landfilled. [x]
(Figure 2: Hazardous smoke from fires at a plastic-to-fuel AR plant in Ashley, Indiana)
Finally, the failure rate for AR enterprises is high. In recent years, over two dozen AR facilities commenced activities in the U.S., but only eight remain in operation. [xi] In some cases, companies declaring bankruptcy have left behind stockpiles of plastic waste.
Several problems contribute to AR failures. Expensive chemicals and high amounts of energy are needed to break down plastic polymers. Next, product yields are uncertain when laboratory experiments with known plastic types are upscaled to industrial levels using mixed plastic waste. Lastly, the > 10,000 additives in plastic products make safe handling problematic. [xii]
Let’s Look at Risks and Options to Solve Waste Problems
In sum, municipal leaders need to take an in-depth look at any proposal for an AR facility. This industry’s record has shown serious harm to communities in several cases and high uncertainty overall. These factors are essential in risk analysis efforts crucial in municipal planning. Furthermore, property values, the cornerstone of municipal revenue, are closely linked to increased risk for threats to local air or water quality. For example, regarding the latest major contaminant, PFAS, legal and financial organizations are working to create metrics for the change in value and insurance risks for real estate impacted by this persistent substance. [xiii] Also, the American Society for Testing and Materials includes the presence of ‘forever chemicals’ such as PFAS as a “business environmental risk” in site assessments required for property development. [xiv]
One option for municipal leaders facing AR and other hazardous industries rests in updating ordinances. Without adequate land use ordinances, a municipality has no ability to reject applications for facilities like AR that pose a threat to public health. Across the U.S., cities are enacting such ordinances. The author of a study on planning for pollution prevention writes, “Indeed, the Clean Air Act itself expressly recognizes the important role of local as well as state governments in addressing air pollution. Municipalities may choose to adopt and enforce health codes to protect residents from various air pollutants that cause or aggravate health issues such as asthma.” [xv] Municipalities should ensure they have land use ordinances in place that enable them to safeguard against the public health and environmental impacts associated with AR or similar facilities. Municipal leaders in New Hampshire should consult with their town planner.
(Figure 3: Volatile Organic Compounds (lbs./yr) from Advanced Recycling of Plastic Waste (PW) vs. Large Incinerators (Standard rates of 250 tons/day)
Another concern for municipalities is solid waste, and advertisements for AR often present this industry as a partial solution to waste problems. Town leaders, however, might benefit from taking a step back to consider whether the AR industry may actually be perpetuating and even expanding plastic production, consumption and waste. In contrast, leaders could look at new opportunities to cut waste itself. For example, two approaches described below reduce waste and may decrease costs as well: composting food waste and reducing plastic overuse. Composting redirects food waste, a large portion of the weight and cost of waste haulage, and it benefits local farms. Legislation that prioritizes composting (informally known as a “food scraps ban”) has proven highly effective at both diverting waste from landfills and bolstering state economies for Vermont and Massachusetts, for example [xvi]. Municipalities and partner companies operating curbside or drop-off food waste collections can get grants from at least five EPA programs, two USDA grants and several other organizations. [xvii] To curtail the plastic waste stream, grants from governmental or non-governmental groups can help schools, nonprofits and businesses substitute reusable food service ware for throw-away plastic. [xviii] To reduce plastic trash in curbside collection and along roads, many states and cities have policies and ordinances to substantially cut single-use-plastic. Eight states including Maine and Vermont have banned single-use plastic bags, as have municipalities. [xix] Also, the 10 states that enacted bottle deposit/return laws enjoy over 70% reduction in litter from containers. [xx] Finally, a rapidly growing new business is thriving in New Hampshire and elsewhere - the refillery, where plastic containers of personal care and cleaning products are refilled, and customers can purchase non-plastic alternatives.
Going forward, municipalities – municipal leaders and planning boards – face increasingly complex risks that warrant robust planning and land use regulations as they make major decisions, especially regarding prospects of a new and largely untested, opaque industry that goes by the industry’s moniker, “advanced recycling”. Examples from other states not only illustrate the full picture of risks for AR impacts, but they also show encouraging alternatives to solve waste problems and keep the Granite State healthy and economically vibrant.
Cynthia Walter is a biologist whose 35-year career has focused on pollution abatement, including collaborations with state agency scientists and county emergency planners. Susan Richman is a Board member of the New Hampshire Network for Environment, Energy and Climate. Both authors have experience serving on municipal committees in New Hampshire.
Footnotes -
[i] NH Law: Title X Ch. 149-M Solid Waste Management. I-a. " ‘Advanced recycling’ means a manufacturing process for the conversion of post-use polymers and recovered feedstocks into basic raw materials, feedstock chemicals, and other products like waxes and lubricants through processes that include pyrolysis, gasification, depolymerization, catalytic cracking, reforming, hydrogenation, solvolysis, and other similar technologies. ... the primary products of advanced recycling shall not include hydrocarbons which are marketed, sold, or used as fuel for energy. Incidental products may be used for fuel only within the facility. For the purposes of this chapter, ‘advanced recycling’ shall not be considered solid waste management, solid waste processing, waste processing, treatment, incineration, or combustion.”
[ii] NH solid waste laws (RSA 149-M) employ a permit system for facilities that manage solid waste and require a proposed facility to be a Public Benefit as described by regulations. From Wimsatt 2021 presentation: “Public Benefit Requirement RSA 149 -M:11, III. Solid waste facilities must provide a substantial public benefit … provide capacity for NH-generated waste; … assist state in achieving implementation of hierarchy and goals (RSA 149 -M:2 and M:3; … assist in achieving goals of state and district solid waste plans”... and also “economic viability.” Presentation on RSA 149-M and Regulation of Solid Waste in NH
[iv] NH Title X Ch. 149-M. I-a allows “incidental products” to be used for fuel in the facility, and this can be over 50% of the plastic waste input.
[vi]https://www.cnn.com/2023/04/11/us/richmond-indiana-recycling-plant-fire/index.html.
[viii]Values based on air permits for Purecycle in Ohio and Brightmark in Indiana, and state agency websites for incinerator emissions for Covanta Indianapolis Inc. and Wheelabrator in Concord, NH.
[ix] Hseih et al. 2021.Benzene emissions from gas station clusters: a new framework for estimating lifetime cancer risk. Journal of Environmental Health Science and Engineering 19:273–283
[x]https://www.reuters.com/investigates/special-report/environment-plastics-oil-recycling/
[xi] ibid.
[xii] Weisinger et al. 2021. Deep Dive into Plastic Monomers, Additives, and Processing Aids. Environmental Science & Technology 2021 55 (13), 9339-9351
[xiii]https://www.natlawreview.com/article/pfas-what-you-need-to-know-transactions
[xiv]https:/www.nhbr.com/pfas-due-diligence-and-what-they-mean-for-real-estate-development/
[xv] Baptista. 2019. Local Policies for Environmental Justice: A National Scan (planning.org)
[xvi] VT’s success: Belarmino et al. 2023 Impact of Vermont's Food Waste Ban on Residents and Food Businesses. Col. Ag. Life Sci. Fac. Pub. 198., https://scholarworks.uvm.edu/cgi/viewcontent.cgi?article=1201&context=calsfac and MA’s success: MA DEP Commercial Food Material Disposal Ban, Commercial Food Material Disposal Ban | Mass.gov
[xvii] Links for EPA, USDA and several other sources are available from the authors or M. Nork at the NH DES Waste Division.
[xviii] https://www.plasticfreerestaurants.org/subsidy
[xix] The National Conference of State Legislatures https://www.ncsl.org/environment-and-natural-resources/state-plastic-bag-legislation
[xx] The Container Recycling Institute: https://www.reloopplatform.org/wp-content/uploads/2021/06/DRS-Litter-Fact-Sheet-Summary-14June2021.pdf