I don't think the process would have worked that way GWMAN. I think you are putting the best possible face on a situation where JBI did not consider some basics in terms of requirements up front. Perhaps if they had had some exploratory discussions like those other P2O companies did before deciding to proceed they would have seen this.
Actually I should have seen this because I have spent years in Waste Management environments working on Water (Sewage) and Wastewater Treatment projects and now in Nuclear Waste control. I can tell you one thing, it is an expensive business. The storage, control, and environmental management of whatever the feedstock for JBI is is a cost item that will certainly add to the quoted $10/barrel cost.
To begin with, there has been much discussion about JBI as an alternative to landfills. Well, landfills are tightly regulated. I know for a fact they all have liners to prevent leaching. Liners cost money. Landfills need permits and are regulated. Therefore, if jBI is going to take waste that would otherwise go to a landfill they can't just have a pile, they have to have a controlled environment.
Nuclear waste management is a sinkhole of government money for every country that utilizes nuclear power. Hugely expensive...
Now as a comparative example, consider a mining operation and wastewater. Wastewater is water that MAY have contamination as a by-product of industrial activity. One project I worked on was to control (I forget how) flow of effluent into a local river. So, in practical terms anybody can understand, all this was was rainwater that landed on the site and flowed across the property into a local river, carrying with it sediment from the mining operation. The uninformed would think that the amounts in question are inconsequential... well they are not. I remember the allowable emission into this waterway and I was blown away. It was a figure in PPM (Parts per Million).
So here we have someone building a process that requires 20T of plastic per day. That is alot of plastic. If the feedstock is unsorted, unwashed plastic... well you have a contamination issue that must be dealt with.
With even a minimum of consideration JBI should have seen this coming. I am sorry, but this is total incompetence. IN FACT, THIS IS/ WAS MORE IMPORTANT THAN THE AIR PERMIT WE HAVE BEEN HEARING ABOUT. JB has always maintained that ALL HE NEEDS IS AN AIR PERMIT. Not true... he needs a Solid Waste Management Permit. Now, the BUD is an exemption... basically it means he does not need the Waste Permit after all. But this is after-the-fact. DEC would be giving hima break, and JBI must show that they will not pollute...
As for your explanation that this had to be tied to the allowable limit for air emissions? And working backward to discover there is a potential issue with waste plastic storage? No, that does not make sense. At 20T/day/ processor we are talking about alot of plastic in any case, so not likely.
What should have transpired here is an analysis of the profitability of a 3-processor installation at that site. That would result in an ROI. As a part of that the regulatory requirements regarding waste storage would have been discussed (with the DEC) and revealed. This issue should have come up. A Waste Management plan should have been devised and factored into the cost.
To say that a company applies for a permit, and as a result of the allowable emissions, designs their process to suit is illogical. They need to scale the operation for success first, then get a permit that matches that need.
Waste Management is a huge issue that should have been considered...
They may or may not get that BUD. They will not get the BUD if they are going to harm the environment, and they need 20T/day, that is quite a logistical challenge if they want to be totally JIT (Just-In-Time)..!!!
It will happen when ... 
AI
