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Rawnoc

11/26/10 10:53 PM

#78796 RE: Johnik #78794

registration provisions of section 360-1.8(h) of this Part, rather than the permit provisions of this Part



Mark Hans, the decision-maker, would likely agree with you. He's in charge of a department located in the same town (or one over?) as JBII's processor and not 6 hours away in another city with an unknown title making "recommendations"

Justice37

11/27/10 12:09 AM

#78810 RE: Johnik #78794

JBI doesn't need a solid waste permit from what I found on the website.

www.dec.ny.gov/chemical/23680.html

"Recycling Facilities
Facility Status

Recyclables Handling and Recovery Facilities (RHRF) - RHRF receive recyclables that have been separated from the waste stream for further separation or processing. RHRFs serve as a processing link for many municipalities and businesses to allow them to get their materials into the recycling system. These facilities are required to be registered with (rather than permitted by) DEC."

The plastic that JBI gets has been separated from the waste stream. Seems it only needs to be registered.

Much of what you have described are when waste products are used to run a furnace. Plastic is not used to run the P2O machine, it is fueled by one the end products of the process, propane, which is pumped back into the P2O processor after it is converted from plastic. In regards to the pyrolysis issue, pyrolysis is not what happens with P2O, at least according to your definition, the plastic is not decomposed, it is converted, there is a difference.

Your research seems to have gone down the wrong path. I'm not an engineer either, I could be wrong but it doesn't look like it.

ABIGIDIOT

11/27/10 12:13 AM

#78811 RE: Johnik #78794

yeh, heres a thought:

JBII will need every permit imaginable, and some that arent even invented yet, before they are allowed to go into commercial production with the P2O process.


GUARANTEED.


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.

Zardiw

11/27/10 11:26 AM

#78852 RE: Johnik #78794

Great research. So according to their own rules, a SWP is total overkill and not needed:

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,

z

fourkids_9pets

11/27/10 12:24 PM

#78861 RE: Johnik #78794

always a pleasure to read your posts ~

--
4kids
all jmo