Thanks for your reply. You make some very good points. You are likely correct that P2O is not "pyrolysis," as that term is defined under the DEC solid waste regulations. (To be clear, it wasn't my definition of pyrolysis. I took it verbatim from the solid waste regs.) That would render the remainder of my post moot, since the rest of it dealt with the regulation of solid waste pyrolysis facilities (again, as so defined for purposes of Part 360).
I haven't looked into the possibility of RHRF status yet. I have a kid pulling on my shirt sleeve right now, so that will have to wait until later.
Thanks again.