My Contribution to EPA CRT Cullet Discussion

This was my comment to the organizers and regulators in the meeting about CRT Cullet Markets (see agenda at bottom):
We were involved in the sale of CRT cullet from an alleged "pile" in the southwest which was widely speculated to be non-moving.

Cullet from the pile was sold (not through us but using our smelter's same trucking company) to a lead smelter in Mexico, which paid 7 cents per pound.

After the 2010 SEMARNAT border controls on the CRT cullet, the Mexico lead smelter said the material was a "headache".  They changed in 2012 to charging 7 cents per pound instead of paying 7 cents for the exact same material.  That is a change of 14 cents per pound based on nothing but "diligence" which equated (to the mining/primary smelting company) as "risk".

This discussion is inadvertently creating justification for companies which speculate on whole tubes, avoiding the cutting and washing.   EPA needs to clearly distinguish between diligence on whole unprocessed material and companies which have turned that material into saleable commodity.

A shredded toaster (steel pieces) should not carry a label of "toaster waste".  It's ferrous metal.  The CRT glass which has been processed should be treated as leaded silicate, and governed by MSDS and DOT etc. according to its properties, not as a "waste".
When we exaggerate the risks of "waste" (attributing more weight to the risk of human-generated secondary material) compared to the risks of identical or higher-risk "virgin" material, we set up bad regulation.  The regulations we have established for "Cathode Ray Tube" glass penalize a smelter if they try it as a feedstock.

The culprit, ironically, may be the word "Stewardship".

lead mining of yore
When we mine gold, copper, tin, iron, tantalum, silver, etc. from mountainsides and Indonesian coral islands, we do massive damage on several scales.  Endangered species are exposed by access roads.  Children mine coltan to fund warloards.   And the number one and number two sources of mercury in the USA are not mercury mining - they are gold and silver mining.   The mountainsides release radioactive uranium, leaded dust, mercury, etc.   Fourteen of the fifteen largest Superfund Sites in the USA have been hard rock metal mines.   But the mountain is not a "Steward".

We still govern mining based on the General Mining Act of 1872.   How can recycling compete with standards of yore?

When we mine urban ore from cities and states, the state officials classify the material as "waste" (increasing their job security as actual was diminishes per capita, and unlined landfills go away).   So they attach "Stewardship" as a fetish that follows along the material.

Leaded silicate, whether from CRT glass or from quartz or from mined slag, has limited risk potential.  Vitrification is the safest form of lead storage.  It's like leaded glass crystalware.  Heck, we could probably ship all our leaded CRT cullet to cap exposed uranium mines, or to bury nuclear plant waste.  It can be exposed to rain and nothing leaches out if you don't grind it up (TCLP test).

The "fetish" which is attached to the "secondary material" from urban mining isn't just a moral "Stewardship" risk.  It's a legal exposure risk (OEMs are afraid loads will be tracked back to programs they funded).  And it's a regulatory tracking risk.
  • We've tagged recyclers as "Stewards" of pile A, secondary material which would have been waste.  The pile has X parts per million lead, Y parts per million silica.   
  • Beside pile A there is a pile B, mined lead ore, and quartz, feldspar, or other silica.   Pile B has X parts per million lead, Y parts per million silica.

Anything which gets in the way of environmental science and lifecycle is environmental malpractice.  We have an opportunity to reduce the mining of pile B, and to divert the waste from Pile A.  Let's get out of the way.

Meriam Webster has other definitions of "fetish", but this one is what I mean.

Definition of FETISH

a : an object (as a small stone carving of an animal) believed to have magical power to protect or aid its owner; broadly :a material object regarded with superstitious or extravagant trust or reverence
b : an object of irrational reverence or obsessive devotion :prepossession

The primary mining industry could take care of all the CRT glass in the world.  If you put all the CRT glass in the world in a big pile in the desert, near a copper mine, it would be smaller than the slag piles, which have the identical silica and lead.   It might not be used in 365 days.  Mines wait to process material based on demand, and the London Metals Exchange.  They don't say that mines are "exhausted", they say that the amount of lead, gold, copper etc. in the mine will be economically recoverable when the raw material is X and the price of energy is Y (secondary material saves energy and carbon compared to digging it out of mountains and refining it to blister copper quality).

By raising the specter of "speculative accumulation", Transparent Planet and EPA have attached a regulatory risk, a "fetish".   They think that Stewardship means that I should care more whether a pile of leaded quartz came out of my house than if it came out of a mountain.  That's bad science.

Good science is that the recycling hierarchy is well studied and valid.   Reuse, Reduce, Recycle.  Any regulations which impede that will be written down as a mistake in the scatalogically obsessed history of environmental health management.



Multi-stakeholder Meeting to Discuss CRT Management and Regulations

May 21, 2013

10:00am – 2:00pm

CEA offices @ 1919 S. Eads Street, Arlington, VA

Meeting Goal  

Bring together thought leaders from industry, the regulated and regulatory communities to discuss challenges and opportunities to responsibly recycle CRT glass in the United States.  

Hosts, CEA, ISRI and ERCC

Facilitator, Lynn Rubinstein, NERC

Welcome and Overview (10:00-10:30)

I. Welcome (Lynn) and Anti-Trust Review  (CEA attorney) 

II. Purpose of Meeting  (Harris, Cifrino, Alcorn) 

III. Participant Introductions 

Understanding the U.S. CRT Market (10:30-11:30)

IV. Review of Recent Survey Data (Rubinstein, Roman)

V. What do the survey results mean? Identify key challenges (facilitated by Rubinstein)   

Review the Regulatory Framework and FAQs (11:30-12:30) 

Working LUNCH

VI. U.S. Environmental Protection Agency FAQs on the federal CRT Rule (EPA representative, TBD) 

VII. California (Hunts) 

VIII. Discussion of regulatory issues (facilitated by Rubinstein)  

Market Driven Solutions (12:30-1:30) 

IX. Discussion of CRT Challenge (Harris and Alcorn) 

X. How is CRT management  affected by certification & auditing programs (Keough and DeVries) 

Building Consensus (1:30-2:00)

XI. Consensus areas of agreement, next steps (facilitated by Rubinstein) 

Adjourn (2:00)

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