     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
                                       
                             OFFICE OF CHEMICAL SAFTEY
AND POLLUTION PREVENTION
MEMO TO DOCKET #EPA-HQ-OPPT-2020-0548
From: Richard Garrison, Nationwide Foam Recycling
Date: July 1, 2021
Subject: Small entity representative comment on HBCD rulemaking

Find attached: Richard Garrison's written answers to questions that were asked by US EPA at the Small Business Panel Outreach meeting on June 17, 2021. 












	





From: Richard Garrison <richard@nationwidefoam.com> 
Sent: Thursday, July 01, 2021 8:56 PM
To: Muellerleile, Caryn <Muellerleile.Caryn@epa.gov>
Subject: RE: EPA Pre-Panel Outreach Meeting on HBCD Risk Management under TSCA - written feedback by July 1

Hello Caryn:

Please find attached my answers to the questions you provided to us.

Thank you for involving us in the process.  I am hopeful that we can continue this dialogue as I believe there are ways to recycle and reuse this insulation that has a net positive affect on the environment and our country at large.

Thank You

Richard Garrison - VP
Nationwide Foam Recycling
Office 508-532-1802 Mobile 508-509-0225
richard@nationwidefoam.com  www.nationwidefoamrecycling.com











Attachment:
SER: Nationwide Foam Recycling  -  responses below (in bold italics)
EPA's SBAR Pre-Panel Outreach Meeting with Small Entity Representatives on Proposed Rulemaking for Cyclic Aliphatic Cluster (HBCD) under TSCA Section 6(a
5) Questions for recycling and reuse operations
a. Do you recycle EPS insulation board, XPS insulation board, or both?
We reclaim both EPS and XPS from large re-roofing projects throughout the country.  EPS is normally recycled (densified and sold as a feedstock) and XPS is normally sold "as is" into a reuse market (repurposed).
b. What new products do you produce from recycling of insulation boards? 
We do not produce "products" from recycling EPS insulation board.  We produce densified EPS "bricks" that are sold to product manufacturers, predominantly exported to styrene picture manufacturers in China.  We have also sold to domestic manufacturers of styrene architectural molding.
We do not recycle XPS insulation boards, we move them to reuse markets.  As such, they are sold as reclaimed rigid foam insulation.
c. At your facility, are insulation boards recycled by themselves or mixed with other recycling feedstock? 
NFR sends EPS insulation boards to companies throughout the country with EPS recycling lines that are most proximate to each jobsite that we service. EPS collected from jobsites in New England is sent to our sister company's recycling facility in Framingham, MA. NFR's office is co-located at the Conigliaro Industries 85,000 sf recycling plant.
EPS insulation boards are a very low percentage of the feedstock moving through processing lines of companies that we deliver to.  My rough estimate is that for every load of EPS insulation we deliver to these companies they will process 100 loads or more of EPS bracing/packaging scrap.  Some will mix the two streams together and some will run the insulation boards as a separate batch.  Depends on how much EPS they have in the plant waiting to process.  At our (Conigliaro Industries) facility in Framingham, we typically run the insulation boards as a separate batch.
I know there are some, however I am not aware of any facility that we deliver to that recycles XPS.  I think that is mostly due to the fact that XPS is not normally used in bracing (which is where the scrap volume is) and the fact that reclaimed XPS insulation is much more valuable "as is" than if densified and sold as a feedstock for new product.
d. Do you reuse EPS insulation or XPS insulation board or know of any reuse?
100% of the XPS we collect is sold "as is" for reuse/repurposing
90% of the EPS is recycled, 10% reused.  Recent shortages of new rigid insulation has changed the trend  -  our customers will now buy reclaimed EPS as a substitute for new polyiso so moving more EPS to reuse than recycle in past several months.
e. Do you mainly facilitate recycling and/or reuse? 
See d. above.
f. What materials are recovered when EPS and XPS insulation boards are recycled? 
XPS and EPS Rigid Foam Insulation Boards  -  typically 2'x8' and 4'x8' sheets in varying thicknesses ranging from 1"-6" thick.
We also collect/reclaim single ply polymeric membranes (EPDM/PVC/TPO) from re-roofing projects,
g. Are you able to identify whether insulation boards contain HBCD? What would it cost if you were required to track them in your recycling process?  
We have never tried to do identify insulation boards that contain HBCD.  Is there a simple burn test available?  We have experience identifying different plastic resins via burn tests  -  melt temperature, smoke color, drip.  We also ID various carpet fiber types using spectroscopic analyzers (lazer gun).  The lazer gun was fairly expensive, $800?
Given that most of the re-roofing projects that we service were last roofed 15-20 years ago perhaps just knowing the age of the roof may be one simple way to evaluate the likely presence of HBCD insulation.
It would not be particularly difficult or expensive to track the flow of insulation boards.
h. What is the value of discarded insulation boards that you recycle? 
Reclaimed XPS insulation boards are typically priced at $.21 per board foot (1'x1'x1"thick).
EPS insulation (densified) ranges from $.11/lb to .$26/lb in 40,000 lb lots.  FOB shipper. 
How much EPS board and XPS board do you recycle? 
We average:
 2.5 million board feet (400,000 lbs) per year of XPS that is collected and sold into the reuse market "as is"
 1.7 million board feet ((123,000 lbs) per year of EPS that is collected and delivered to recycling facilities for densification and ultimate sale to manufacturing facilities as feedstock
What percentage of your total recycling revenue is from insulation board? 
97% (includes polyiso)
j. How would it affect your business if EPA prohibited recycling of insulation boards containing HBCD?
If we were prohibited from recycling EPS we would loose about 10% of our revenue stream
k. How would it affect your business if EPA prohibited reuse of insulation boards containing HBCD?
If we were prohibited from reusing XPS we would loose about 60% of our revenue stream and have to either find new materials to replace the revenue with shut down the company
l. What would it cost if EPA required you to reduce levels of HBCD in indoor air to reduce or prevent release to outdoor air? Examples of requirements: 
 Segregation of operations into separate rooms  -  $0, already in place
 ii. Monitoring of respirable dust in work area  -  ? 
 iii. Reducing the speed of equipment  -  We estimate that it costs about $.11 per lb. to densify EPS for recycling.  Labor is at least half of that cost, say $.06 per lb. So a 50% decrease in speed would increase our costs by 25%. 
 iv. Increasing the amount of recycling back into the manufacturing process  -  N/A we do not manufacture 
 v. Use of particular containers and equipment that prevent releases - What would these be? 
 vi. Cleaning protocols such as sprays to knock down dust  -  We used to make a rough packing peanut called "polycorn" that were just small balls of broken EPS.  We used a mister on our breaking line to reduce the "static cling" of the polycorn balls before they conveyed into large bags.  Our current process is just a breaker that sends the broken pieces into a compression chamber where it is densified.  The breaking process creates a substantial static charge and EPS beads that are released during the breaking process cling to everything near by.  It works a bit like the first stages of an electrostatic precipitator.  I would be surprised if any significant levels of EPS dust exist in the air around the process line  -  everything is clinging onto the machinery!  Could this be an opportunity to capture any particles that could cause harm? Would EPA consider doing some testing at our facility to quantify the dust levels?
 vii. Exhaust systems  -  We have a large ceiling vent fan in the EPS recycling room that vents to the outside recycling yard.  We sit on 7 acres in an industrial zone bordered by railroad tracks on one side and solar panel farm on the other.
 viii. Filters on exhaust mechanisms to prevent pollution in local community  -  Yes possibly.
 ix. Use of closed systems to protect workers  -  not sure this is practical  -  better to use respirators.
 x. Hoods or other containment on equipment - possible 
 xi. Numerical limits on HBCD dust or modified foam dust in indoor or outdoor air - ?
m. What would it cost if EPA required you to do more to prevent HBCD dust from entering streams, rivers, or lakes, in your experience? Examples: 
 Facility or equipment cleaning ii. Spraying water at outdoor site to reduce fugitive dust  -  I don't think it would be expensive to create a misting system over the breaker or conveying line.  This is doable. 
n. Do you have recommendations for EPA?
 Consider the benefit of our services to the environment. Balance the environmental impacts of recycling and reusing HBCD containing insulation with the alternatives which are landfilling and waste to energy.  Very significant reduction in energy inputs and carbon emissions  -  especially when the XPS is reused.
 Consider the benefit of our services to our roofing customers.  Our EPS/XPS services eliminate the costs of disposal for the roofing companies and the building owners when they re-roof.  This is significant  -  a typical 200,000 sf re-roofing project will normally generate 10 tractor trailer loads (1,000 CY) of used rigid foam insulation.  At typical disposal costs of $15 per CY this results in $15,000 in disposal cost savings for that project.
Consider the benefit to our customers.  Most of our customers are DIY people, using the XPS insulation to insulate below concrete slabs and exterior foundation walls.  They buy our product for half of what they would pay for new and are tickled pink.
