Plastic2Oil Inc (PTOI)

[Johnik]

Random thoughts on solid waste permits.

Given that it has never been clear whether or not the solid waste permit would be required of JBI, I never really bothered looking into this issue. This evening I saw that there has been more discussion of this issue, so I thought I’d poke around on the DEC website to see what I would find. I thought I’d share a few observations.

Obviously, the folks at the DEC or at JBI are a better source of information on what is or is not required of P2O, so this post is merely academic. If you are looking for facts or updates, don’t bother reading further.

I started with the premise that JBI’s feedstock would be considered solid waste, and that P2O would be considered a solid waste management facility, thereby bringing it within the solid waste regulations that I have seen referenced on this board (i.e., Part 360). For those who would like to read about what "solid waste" is under the DEC regs, you can do so here:

http://www.dec.ny.gov/chemical/8732.html

There have been plenty of posts on BUDs as well, so I won’t go into that either, but you can read more on that topic here if you like:

http://www.dec.ny.gov/chemical/8821.html

So, as I was reading, the first thing that caught my eye was the term “pyrolysis,” since I have seen that term come up many times during discussions. I’m not a tech expert, so I’ll need some help from some of our tech/engineering experts to see if I am on the right track at all. Here is the definition of “pyrolysis” for purposes of Part 360 (found in section 360-3.2(d)):

Pyrolysis means a process using applied heat in an oxygen-deficient or oxygen-free environment for chemical decomposition of solid waste.

http://www.dec.ny.gov/regs/4413.html#14666


If “the shoe fits,” then there is potentially a third possibility for JBI. Section 360-3.1 allows for registration (rather than more onerous permitting) of solid waste pyrolysis units that meet certain requirements (found in section 360-3.1(c)):

Registration. An energy recovery incinerator or solid waste pyrolysis unit that accepts off-site generated solid waste as alternate fuels is subject to the registration provisions of section 360-1.8(h) of this Part, rather than the permit provisions of this Part, provided such waste is nonhazardous, nonputrescible, recognizable, unadulterated and uncontaminated and:
(1) the storage of solid waste prior to combustion or pyrolysis must be located on surfaces capable of minimizing leachate release into the groundwater underneath the site and surrounding land;
(2) all leachate must be collected and treated by a method approved by the department;
(3) an annual report must be prepared and submitted to the department in accordance with section 360-3.4(f)(3) of this Part; and
(4) representative samples must demonstrate that the alternate fuels have a minimum heating value of 4,000 Btu per pound as-received.

(emphasis added)
http://www.dec.ny.gov/regs/4413.html#14667


Under the above-referenced section 360-1.8(h), it appears that the facility would be eligible to obtain life-long registration, subject to more limited “ministerial action,” without being subject to the Uniform Procedures (Part 621) that are applicable to other permitting. Possible?

http://www.dec.ny.gov/regs/4415.html#14629

Again, these are just random thoughts and observations due to an evening of curiosity, not a reflection on what is actually required. Anyone wish to chime in with some thoughts? Just some playful brainstorming here...the decisions are obviously up to the DEC.