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02/01/20 6:38 AM

#306146 RE: loanranger #306145

Read through P2O's solid waste permit, and their Air Facility permit

The only plastic they're allowed to use is post-industrial, pre-consumer plastic waste, where the entire chemistry is known.

If the plastic came from a sorted municipal waste stream, that's not valid for use.

I'm sure the NYS DEC has imposed these restrictions to keep PVC out of the mix.

Detailed Description of the Process for Procurement of the
Plastic/Waste Oil Feedstock
JBI will carefully review potential sources of
non-recyclable grade plastic for use as a raw material
feedstock. This material will be acquired from the
industrial market place. Plastic types which have been
determined to be acceptable for utilization as feedstock
include: Polypropylene (PP), Low Density Polyethylene
(LDPE), and High Density Polyethylene (HDPE). No
Halogenated plastics such as Polyvinyl Chloride (PVC) will
be accepted by JBI.
All sources of plastic and waste oil feed will be
prequalified by JBI personnel before agreeing to accept
the material. This prequalification procedure will
consist of visual inspection by JBI personnel, review of
the MSDS for the material where available, and possible
test results from material samples when testing is deemed
necessary. Typical plastic materials which can be
utilized as feedstocks include plastic parts and cuttings,
packaging film, shopping bag film, strapping and mixed
color regrind. These materials are typically produced by
vacuum forming, injection molding, casting, or
tooling.
Off-spec Crayola products directly from the manufacturer
and a small portion from recycling efforts at schools will
also be used as a feedstock in cubic yard containers and
staged at the facility and fed into the reactors. Waste
oil is sourced from local waste oil management companies,
U.S. Steel, and other waste oil sources. The sourced
waste oil will meet requirements of 6NYCRR Part 225-1 and
225-2. Most waste oil management companies pre-test their
shipments and provide certifications with the waste oil
trucks. U.S. Steel does not have an in-house waste oil
testing laboratory. If a supplier does not supply a
certificate of analysis upon arrival, the trailer will be
tested at the JBI in-house lab prior to unloading the
truck. If the in-house lab at JBI confirms the oil meets
the requirements of 6 NYCRR Part 225-1 and 225-2 then the
truck will be unloaded. In the event the load is
unacceptable the load will be returned to the generator or
shipped to an approved waste disposal facility.
The chemical composition of all plastic materials and
waste oil must be compatible with the capabilities of the
JBI process. It must not be contaminated with materials

Permit ID: 9-2911-00348/00002 Facility DEC ID: 9291100348
Air Pollution Control Permit Conditions
Renewal 1 Page 12 FINAL
which could result in detrimental impacts during
processing.
All plastic must be shipped in enclosed weather tight box
vans. Waste oil must be shipped in appropriate trucks
meeting DOT requirements.
Upon receipt a log sheet will be utilized to retain
information as follows:
Source of plastic or waste oil
Name of transporter
Date and Time of receipt at JBI site
Amount of plastic or waste oil in each shipment (Weight,
Gallons, or Cubic Yards)