Soooo...what's the hold up? .....TODAY!
I SAY "TODAY" BECAUSE... well for lack of better amusements it seems certain "SPECIAL" folks keep coming up with "new and depraved" reasons for their accusatorial lamentations as to how the "company" or worse the "CEO" has deliberately or negligently screwed this all up in yet another "ode to puppy factory" FASHION.
Yet we hear, just today, rumors that some brownshoe, just this past wednesday, "decided" on something of a SW registration or permit WILL be required. Which really does not surprise me as a while ago, when this was first raised, I too, read some DEC website jargon talking about pyrolysis machines and the like, rather than get all wound up in it, I chose to allow the powers that be sort it out.
Have not been around much for a spell and much to my surprise this is STILL "TOPIC DU JOUR" so here's my take on the lighter side of it all.
To BUD or not to BUD, is that really the question?
Arguements for or against don't mean much considering the BUD application is reportedly already filed, and until DEC determines this BUD's for JBII and reviews and approves that BUD application, arguing the point is...well.....FRIGGEN STUPID!!
Now for something completely different.
Solid Waste Management Facility Registrations & Permits
On the rumor of the SW permit being required.
2-4 months to complete after application received?
Really?...and how long to get up to code before the application can be filed just to begin that 2-4 months waiting?
If Lovethatgreen and purportedly others were told the same thing, it might very well be correct as that waiting period is much longer than simple SW facility registration.
But in the fear that "This BUD's NOT for JBII, and something to do with SW will be required one MIGHT hope the prep to file SW "registration" is already underway as it needs to be
"submitted to the office of the department administering the region in which the facility is to be located, on a form prescribed by or acceptable to the department, at least 30 days prior to undertaking the activity proposed for registration."
who knows.....certainly not me lol...but if registration becomes the way to "get er done" here is the basic game plan. Some of the more important shyte is bolded as is stuff needing doing before the registration application being filed.
"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,
(h) Registration of facilities.
(1) Certain regulated solid waste management facilities may be eligible for registration rather than the permit requirements of this Part, under prescribed thresholds and conditions specified in this subdivision and under each appropriate Subpart of this Part.
(2) Registrations are ministerial actions for purposes of Part 617 (State Environmental Quality Review) of this Title.
(3) Registrations are not subject to Part 621 (Uniform Procedures) of this Title.
(4) Registration forms must be submitted to the office of the department administering the region in which the facility is to be located, on a form prescribed by or acceptable to the department, at least 30 days prior to undertaking the activity proposed for registration.
(5) The owner or operator may not undertake a registered activity until they have received a validated copy from the department of their registration. If a facility proposed for registration requires other department permits, or otherwise does not meet the conditions and requirements specified in this Part, the department may disapprove a registration and require a permit application rather than a registration.
(6) Registrations for appropriate facilities are generally valid for the life of the registered facility and may be transferred only upon prior written approval by the department.
(7) Registered facilities may not be exempt from other applicable requirements of this Part.
(8) Registered facilities must submit an annual report, on forms prescribed by or acceptable to the department, to the department's central office and the office of the department administering the region in which the facility is located, no later than 60 days after the first day of January following each year of operation. The report must include, but not be limited to: the total annual amount of waste received by weight or volume, compiled by type and quantity received during each calendar quarter; the origin of the waste received; the destination of the waste removed; the weight or volume and type of each material recovered; and, a description of any problems encountered and methods for resolution and any changes in operation that have occurred in the previous year.
(9) Registered facilities remain subject to the operational requirements of subdivisions 360-1.14(b), (d), (e), (i), (j), (k), (l), (m), (p), (r), (s) and (w) of this Part.
§360-1.14 OPERATIONAL REQUIREMENTS FOR ALL SOLID WASTE MANAGEMENT FACILITIES.
(b) Water.
(1) Solid waste must not be deposited in, and must be prevented from, entering surface waters or groundwaters.
(2) Leachate. All solid waste management facilities must be constructed, operated and closed in a manner that minimizes the generation of leachate that must be disposed of and prevent the migration of leachate into surface and groundwaters. Leachate must not be allowed to drain or discharge into surface water except pursuant to a State Pollutant Discharge Elimination System permit and must not cause or contribute to contravention of groundwater quality standards established by the department pursuant to ECL section 17-0301.
(d) Control of access.
Access to and use of the facility must be strictly and continuously controlled by fencing, gates, signs, natural barriers or other suitable means.
(e) Control program for unauthorized waste.
(1) The facility owner or operator must institute a control program (including measures such as signs at all maintained access points indicating hours of operation and the types of solid waste accepted and not accepted,
(I would add that persitent folks wanting to know the exact type of feedstock would be finally shut up with this last part)
monitoring, alternate collection programs, passage of local laws, etc.) to assure that only solid waste authorized by the department to be treated, disposed of or transferred at the facility is being treated, disposed of or transferred at that facility. The facility owner or operator must develop and implement a program to teach the facility's staff to recognize, remove and report receipt of solid waste not authorized by the department to be treated, disposed of or transferred at the facility.
(2) If solid waste not authorized by the department to be treated, disposed of or transferred at the facility is observed in the solid waste at the facility or delivered to the facility, the facility owner or operator may refuse to accept the waste. If the owner or operator accepts the waste, the owner or operator must remove it, segregate it, and provide to the department a record identifying that waste and its final disposition. The department must be notified of each incident in the annual report and records of each incident must be available for department review. Any unauthorized waste accepted by the facility owner or operator must be managed in accordance with applicable federal or State laws and regulations.
(3) Solid waste not authorized by the department to be treated, disposed of or transferred at the facility that is segregated must be adequately secured and contained to prevent leakage or contamination of the environment. The facility owner or operator must cause it to be removed as soon as practicable, but not to exceed 90 days after discovery, by a person authorized to transport such waste to a facility approved to receive it for treatment, disposal or transfer.
(i) Recordkeeping.
(1) The facility owner or operator must retain records of all unauthorized solid waste accepted identifying the waste and its final disposition. Such records must be summarized in the annual report. They must include the date solid waste was received, the type of solid waste received, the date of disposal, the disposal method and location.
(2) The facility owner or operator must record self inspections as required by paragraph 360-1.14(f)(3) of this Subpart in an inspection log. These records must be retained for at least seven years from the date of inspection. They must include the date and time of the inspection, the name of the inspector, a description of the inspection including the identity of specific equipment and structures inspected, the observations recorded, and the date and nature of any remedial actions implemented or repairs made as a result of the inspection.
(3) Except as otherwise specified in this Part pertaining to a specific type of solid waste management facility, the facility owner or operator must keep records of all data used to develop or support the permit applications and any supplemental information submitted to comply with the requirements of this Part and pertaining to construction of the facility throughout the active life of the facility and the post-closure period. Records pertaining to the operation of the solid waste facility must be kept for a period of no less than seven years from the date they are made or are required to be made, whichever is later.
(4) The facility owner or operator must retain records of all monitoring information (including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation; and copies of all reports required by, or by a permit issued under, this Part) for a period of at least seven years from the date of the sample analysis, measurement, report or application. Existing water quality records must be kept throughout the active life of the facility and the post-closure period. Records for monitoring information must include: the date, exact place, and time of sampling or measurements; the name of the individual who performed the sampling and measurement; the date analyses were performed; the name of the individual who performed the analyses; the analytical techniques or methods used; and the result of such analyses. Additional information relating to the analysis, including records of internal laboratory quality assurance and control, must be made available to the department at its request.
(j) Confinement of solid waste.
Blowing litter must be confined to solid waste holding and operating areas by fencing or other suitable means. Solid waste must be confined to an area that can be effectively maintained, operated and controlled. Solid waste must not be accepted at a solid waste management facility unless the waste is adequately covered or confined in the vehicle transporting the waste to prevent dust, and blowing litter.
(k) Dust control.
Dust must be effectively controlled so that it does not constitute a nuisance or hazard to health, safety, or property. The facility owner or operator must undertake any and all measures as required by the department to maintain and control dust at and emanating from the facility.
(l) Vector control.
The facility must be maintained so as to prevent or control on-site populations of vectors using techniques appropriate for protection of human health and the environment and prevent the facility from being a vector breeding area.
(m) Odor control.
Odors must be effectively controlled so that they do not constitute nuisances or hazards to health, safety or property.
(p) Noise levels.
Noise levels resulting from equipment or operations at the facility must be controlled to prevent transmission of sound levels beyond the property line at locations zoned or otherwise authorized for residential purposes to exceed the following Leq energy equivalent sound levels:
Character of Community Leq Energy Equivalent Sound Levels
7 a.m.-10 p.m. 10 p.m.-7 a.m.
Rural 57 decibels (A) 47 decibels (A)
Suburban 62 decibels (A) 52 decibels (A)
Urban 67 decibels (A) 57 decibels (A)
The Leq is the equivalent steady-state sound level which contains the same acoustic energy as the time varying sound level during a one-hour period. It is not necessary that the measurements be taken over a full one-hour time interval, but sufficient measurements must be available to allow a valid extrapolation to a one-hour time interval.
(1) If the background residual sound level (excluding any contributions from the solid waste management facility) exceeds these limits, the facility must not produce an Leq exceeding that background.
(2) The sound level must be the weighted sound pressure level measured with the slow metering characteristic and A-weighted.
(3) Measuring instruments must be Type 1 general purpose sound level meters, Type 2, or corresponding special sound level meters Type S1A or S2A.
(4) Mufflers are required on all internal combustion-powered equipment used at the facility. Sound levels for such equipment must not exceed 80 decibels (A) at a distance of 50 feet from the operating equipment.
(r) Department-approved facilities.
Solid waste resulting from industrial or commercial operations, sludge, and septage must be processed, disposed, used or otherwise managed only at facilities that the department has specifically approved for such management of that specific waste.
(s) Emergency numbers.
Telephone numbers to emergency response agencies such as the local police department, fire department, ambulance and hospital must be conspicuously posted in all areas where telephones are available for use at the facility.
(w) Closure.
The owner or operator of any active or inactive solid waste management facility must, upon termination of use, properly close that facility and must monitor and maintain such closure so as to minimize the need for further maintenance or corrective actions and to prevent or remedy adverse environmental or health impacts such as, but not limited to, contravention of surface water and groundwater quality standards, gas migration, odors and vectors. Termination of use includes those situations where a facility has not received solid waste for more than one year, unless otherwise provided by permit, or if the permit has expired. Termination of use also results from permit denial or order of the commissioner or of a court. Specific closure measures which may also include corrective actions as specified in this Part are subject to approval by the department.
