Presentation on Utility-Scale solar PV Recycling by Solar eWaste Solutions

The following is a transcript from the Utility-Scale Photovoltaic Module Recycling presentation delivered by Dwight Clark, CHMM and General Manager of Solar eWaste Solutions at the eSummit powered by SERI. For the full presentation, click here or on the presentation image linked.  

Transcript

Hey. Welcome, everybody.

This presentation’s on utility scale photovoltaic modular cycling.
I’m Dwight Clark from Solar e Waste Solutions here to make your day.

So first things first, who is this guy?

K? I get asked this all the time. Who is this guy? There’s a little bio on me.

I’ve talked trash for a lot. It’s a long time. I’ve been involved
with the r two standards since pretty much the beginning. One of the
very first few auditors out there.

I’ve done lots of things in the r two world. I’ve done lots of things
in the recycling world. I’ve done lots of things in the environmental
cleanup world.

So that’s that.

Alright. First, let’s talk how are solar cells assembled. We’re We’re
gonna talk right now primarily about silicon solar modules because
they’re assembled whether they’re dual glass or glass on a backsheet.

They’re assembled all generally the same way.  You can see
Synovoltaics did this nice little graphic that I found online here and
giving them complete credit because I am not the artist.

But it goes through the different steps of how they make solar cells
into a solar module and then put the multiple modules up into an array.

You can see on the lower right hand side where you see a cross
sectional view of the, solar panel. And you can see, you know, the sunny
side and the backside and how it’s a big sandwich with some
encapsulating resin.

 That encapsulating resin goes on as a sheet, and it’s
installed, and it’s heated up, and it does what’s called cross link
polymerization for all the haz waste guys out there.

And it becomes a big sticky gooey mess in between that glass with all
the air excluded, to keep the moisture off the solar panels as well as
provide some electrical insulation. You know? We wanna keep the
electrons off of our fingers where at all possible.

So all this put together, this is mostly provided here to walk us
through why it’s so darn difficult to get this apart. The engineers that
made solar panels made them to last thirty plus years out in the
environment, getting hit by hail, you know, You know? Not necessarily a
direct hit from a tornado or a hurricane, but a great deal of stress and
damage.

So these things are tough.

And then we wanna talk about how do we recycle.

Well, first step in recycling most anything is taking it apart.

So let’s talk about different recycling systems.

 The key questions that somebody needs to ask if you’re doing a
downstream, if you’re getting your stuff recycled, okay, right there,
does size matter? What is utility scale? Are the modules hazardous
waste? And what is appropriate due diligence?

These are all key questions that you wanna ask to protect your liabilities as a generator of solar panel waste.

Be it a manufacturer, a collector, a developer, a solar o and m
operator. You all have the same long term, super fund type liabilities
and why you wanna answer all these questions.

 A typical recycling process.

I suppose that if you’re sitting in this this talk that you’ve looked
into solar recycling more than once, you probably went online and you
found some package units on YouTube or on LinkedIn that are available
from China for recycling the solar modules. I see these ads all the
time. I get hit by these manufacturers all the time. 

Right now, what has been out there until here most recently is
machines and package units that treat a single glass solar cells solar
modules.

 And they can’t currently treat bifacial modules. There’s a few of these units in the US in operation today.

Recently, the same Chinese manufacturer has started a back a dual glass module.

K?

But these units all generally have some throughput drawbacks.

They advertise their best case production rates at sixty to eighty solar modules per hour. 

And so that only allows you to treat less than two hundred thousand
solar panels on one shift in a year, and that’s if you have a perfect
year and don’t have any equipment upsets for maintenance.

 In the utility scale world, we’ve seen several projects in excess of a hundred thousand modules for recycling.

 We’ve seen probably twenty different projects on the twenty thousand plus modules for recycling.

You know, two projects could put somebody completely full for the year, so size does matter.

A typical recycling process.

The current technology does some separation, but the critical
materials are not always clean enough to be a value. What we’re talking
about here specifically is mostly processes operating in the United
States right now.

The silicon doesn’t come out clean enough to be of any value if it’s even taken out at all.

Some of the recyclers out there right now are removing the glass by a
grinding process, and they’re attempting to mix it in with concrete and
other things like that.  The glass generally is too contaminated
to be reused in another glass furnace.

So why is going into concrete bad? Well, if it was a hazardous waste
solar panel, that would be illegal because that would be waste that
would be use constitute in disposal.

Right now, as far as waste classification goes, there’s nothing
specific in the federal law that says a solar panel is hazardous or it
isn’t hazardous.

It says the generator must either use knowledge or testing to determine if something is hazardous.

The method the generally accepted method to determine if something is
hazardous is the ASTM standard that I reference on this sheet here,
ASTM e three three two five dash two one. It gives a very specific
methodology to how you sample the different areas of the solar panel in
order to get a mass based representative sample of the entire components
of the panel.

You can’t just chip a corner off, run it for, test, and say, yeah. It’s not hazardous or it is hazardous.

The generally accepted way according to EPA is going to be taking a representative sample.

And the ASTM standard I provide you there provides you with the
detail on how to do that. We’re quite experienced in doing that. We’ve
taken samples of a few hundred solar panels so far. We have a database
of a few thousand samples that we’ve collected over the last five years.

One thing I will note is for you guys in California, solar panels generally have those copper wire leads on it. 

As you know in California, copper is hazardous above twenty five
hundred total twenty five hundred parts per million total concentration.

K? So that means that copper wire on the back there could make that solar panel hazardous waste in the state of California.

Now this assumes that it’s not able to be used as a solar panel again.

Okay.

So accumulating waste.

Now we’ve talked about could it be hazardous, could it be not, and
you wanna collect it. Accumulating is the next thing you do. 

This is not atypical of any other storage process.

Solar modules are huge, though.

Think about it. Most solar modules that we’ve handled are generally
in the size range of forty inches wide plus forty to forty four,
typically. Some down around thirty seven, but forty to forty four, and
generally sixty seven inches to ninety inches long.

So they’re effectively like a sheet of plywood, weigh about fifty pounds, you know, twenty five or so to the pallet.

It’s not like a stack of laptops for my e waste provider friends.

Also, solar farms are very spread out through the country, and the recyclers are not in every location.

So transportation is a huge environmental challenge, and the trucking distances can be significant.

And as with many other materials, you need to deal with potential releases.

 The universal waste regulation that solar panels are managed
under in some states require that the broken glass be contained.

Same with the hazardous secondary materials rule, requires that the
glass is contained. EPA doesn’t want you leaving a trail of breadcrumbs
leading to my facility.

Okay.

So liability.

There’s two types of long term liability issues for people who
collect solar panels, people who generate solar panels as a waste, and
people who process solar panels.

There is both RCRA and Circa, obligations.

 RCRA is today’s hazardous waste facilities.  Treatment for
hazardous secondary materials, which is the way Solar e waste solutions
treats solar panels. We do it under RCRA as a hazardous secondary
materials.

That way, none of our clients need to sample solar panels. They can
just assume their hazardous. They all get treated following that
process, and then there’s no, hazardous waste liability.

And then circle implications.

Circle implications apply to illegal dumping and things like that. They have a concept called joint and several liability.

And this means, in essence, that anybody related with it. So it could
be the trucker that hauled it. It could be the transfer station that
that set it down and waited to put it on the next consolidation truck.
It could be the operator that took them down or the electrician that
took them down or the e waste provider that collected them. But if it
created a mess at some point in time, everybody in that chain of custody
effectively has some super fund liability.

 How do you avoid the recurrent CERCLA or the super fund liability?

Our opinion at SolarUA Solutions is that you best avoid it by using the hazardous secondary materials exclusions.

 These exclusions let us with proper permitting, proper
insurance, proper operating procedures, and other levels of due
diligence to remove valuable secondary materials from a hazardous waste
stream, get them recycled elsewhere, and then manage everything as a new
waste from that point on.

This is a a beautiful way of doing it. It’s authorized in most states.

 It limits the generator on having to count the material they generate as hazardous waste.

So it provides a convenient method. Additionally, we recommend that
people try and use the Superfund Recycling Equity Act as a defense.

This was put into place by REMA, which we the old ISRI organization,
the Recycled Materials Association now, did a lot of lobbying, got the
Superfund recycling equity act and put in several years ago. And it
allows the recycler, okay, or the generator to do due diligence on their
recyclers and demonstrate that it’s not sham recycling and prevent
having they then have a defense of any super fund related issues when it
were to come from that.

Now, also, I hear people say that scrap metal exemptions may apply to
solar panels much like they do to circuit boards. I have seen EPA shoot
this down a number of times.

So anyone out there that thinks that you can treat solar panels in
the same way you you can e waste will eventually be in for a rude
awakening.

So we talked about due diligence. What’s the appropriate levels of due diligence?

Alright? This applies to an o and m operator building a solar farm,
the investors funding the solar farm, any waste collector collecting
solar panels from households, a transporter, an EPC contractor, pretty
much anybody.

You wanna do some level of due diligence to make sure you’re not gonna be in pro. 

So what’s the appropriate level? The hazardous secondary materials
rule and the Superfund Recycling Equity Act all call out some very
specific items to do.

The questions you have to answer yourself, you have to keep a record of that. 

First question, is the recycling process viable, and does it recycle a valuable commodity?

Alright. Most recyclers out there recycle the aluminum frame. It’s ten to fifteen percent by mass.

Aluminum is a valuable commodity.

So, yes, you’re getting that out there.

But there are many other things that could be a valuable commodity
inside of a solar panel. Do you wanna rest with just getting the
aluminum out?

If you send glass to become cement, is that a valuable commodity?
Because if somebody is not paying for it, it’s not a valuable commodity.
If you’re having to pay to get rid of it, I would be concerned and be
concerned about improper disposal.

So second question it asks is you have to demonstrate, is the
recycler treating the modules as a valuable commodity? Are they all
strewn about in a backyard, unsecured, flopping around, not on pallets,
general storage conditions, general cleanliness of the plant, general
ways they manage them.

Next question you have to answer is, does the recycler have adequate pollution insurance?

 Even if you’re not sending solar panels for hazardous secondary
materials, I strongly recommend that everyone ensure your recycler has
pollution insurance.

One or two million dollars worth of pollution insurance generally
will not pay for a cleanup if something goes fundamentally foul.

Then one of the next things you need to meet is, does your recycler demonstrate they don’t meet speculative accumulation?

 Can they prove processing of at least seventy five percent of their last annual receipts?

The way EPA regulates sham recycling through the speculative
accumulation rule is that if on January one, I have a hundred thousand
pounds on hand, I have to process seventy five percent of that one
hundred thousand pounds prior to the end of the year.

Doesn’t matter what I bring in that year. It’s crazy, but it does.

Now next question she may ask, is the recycling activity meeting the local regulations along in addition to federal?

California won’t let people operate under hazardous secondary materials material exclusions there. They want you to have a full
hazardous waste treatment permit to treat solar panels in the state of
California.

There’s several handlers that can handle solar panels in California, but very few that can treat them.

Alright?

Also, has the facility, your recycler, have they notified EPA of the
recycling activity? Not just having an EPA ID number, you know, and just
FYI everybody, EPA ID numbers are not a permit. They’re just a form
somebody filled in and they got sent back a number. 

The recycling activities aren’t permitted either, but they require some self certification.

They also require disclosure to EPA that you’re doing those and monthly and annual reporting related to it.

And does the facility have a closure plan and a current cost estimate?

Because if you don’t have a closure plan, how do you know what the closure is gonna cost you?

 I’ve reviewed a number of closure plans. Last one that I
reviewed said that it was based on them storing no more than ten
thousand pounds of a material.

When I got there, they had two hundred and sixty two thousand pounds
of the material, and they were upset that I told them their closure plan
was not valid because it would not pay for it would not facilitate and
pay for removal of all that material.

So when we talk about paying for it, how are the closure costs to serve?

The money set aside by foreclosure if you’re a hazardous secondary materials facility is required to be copied to the EPA.

 They guarantee that your money is available for closure and nothing else.

Alright? There’s regulations on how that money is set aside, how it’s isolated, and that sort of thing. 

Next thing you wanna ask, you wanna ask your recycler is how do you
verify their secondary waste or analyze for hazardous characteristics?

I can tell you from experience that I’ve ground up certain solar
panels from a certain thin film panel manufacturer that’s nonhazardous.

When it’s in the field, you grind it up, and I guarantee you’re gonna
have hazardous waste just from the cadmium in it. So you wanna make
sure that the secondary wastes are getting sampled and verified that
they’re not creating hazardous waste.

And then you also wanna make sure the secondary material doesn’t
contain contaminants not found in an analogous product that they’re
replacing.

This brings us to glass colored. Glass colored in the solar industry
from glass made in China is generally contaminated with ten to twenty
thousand parts per million of antimony.

 It’s put in there for very specific reasons in the glass making process to make the glass better for a solar plant.

But glass doesn’t typically contain more than a few hundred parts per million metals.

Alright? And that that antimony contamination of that glass will prevent it from being recycled fully.

So it could cause a problem with the hazardous secondary materials.

More questions you should ask. 

Again, due diligence is all about asking questions. You wanna know, hey.

Is are you making a legal transfer to the next facility if you’re not recovering everything yourself?

So say I had a glass and silicon mixture with metals, and I
transferred it downstream, but I didn’t sample it to see if it was
hazardous waste.

That might be a problem.

And can that facility take it?

Okay. The secondary materials, you gotta be able to demonstrate, provide a useful contribution to the new product.

Also, thirdly, let’s talk about safety really quick. Do you really
wanna be associated with a recycler that has a poor safety record?

The quick easy check is you ask somebody to give you the
certification of their experience modifier ratio. Every business should
be able to get you a piece of paper stating what their experience
modifier ratio is, unless they’re a brand new company. And then they’ll
be able to get you a letter saying, hey. They don’t have one yet. 

But everybody who’s any good is generally gonna have an experience modifier ratio less than one.

Personally, I know that, like, when I did some oil spill cleanups in
the past, we couldn’t work on the BP Horizon oil spill if we had an EMR
greater than one point o five.

Right?

They were that serious about safety.

Most big energy sites are still that way.

If you have an experienced modifier ratio above one point one, you can’t do work for a lot of people.

So it’s a good quick measure. And the easy thing to ask for that nobody can BS anybody on for lack of any better term. Alright.

So now we get to exports. Does your recycler export any secondary materials?

Are they adequately determined to determine regulatory status?

If they’re hazardous, now you have notification and consent. Right?

Now the question is is not only hazardous in the US, but the country is being received in.

Some of the recycling operations I’ve I’ve viewed mix contaminated glass with other materials and send it to smelters.

The silicon and the glass are lost in that process. They become in the slag layer. They’re not necessarily beneficially reused.

 The silver, it is is getting taken out, but it it’s a very small fraction of that material.

Alright.

So now three quick frequently asked questions, alright, for you just to think about.

And I included a link to guidance from North Carolina on hazardous
secondary materials. Probably some of the best guidance out there.

Also, PV glass. If it’s contaminated glass, it’s a negative value.

Just as bad or worse than CRT glass for my e waste friends.

And here’s my contact info.

I’ll be at the show. Give me a shout.

Love to sit down and talk about it. Thank you.