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The PEM® has undergone extensive environmental emissions testing by a number of groups. This testing has been performed on commercial scale PEM® systems (Models G100 and G200) by InEnTec staff or InEnTec customers using third party contractors for the sample acquisition and chemical analysis. For testing conducted in the USA, the sampling contractor AmTest Air Quality, which has extensive sampling experience and uses USEPA sampling protocols, was frequently used. The chemical analyses of the samples were performed by USEPA-Certified laboratories. For tests conducted by InEnTec customers in Japan and Taiwan, similar testing, sampling, and analysis protocols were also used. This section of the web site summarizes the key testing done for regulatory authorities and provides links to documents, reports, and papers associated with the testing or approvals. If there are any questions on the material presented, contact InEnTec. Feedstock Tests / Demonstrations Hazardous Waste Testing The key hazardous waste testing has been the US Environmental Protection Agency’s EvTEC (Environmental Technology Evaluation Program) Program to evaluate new technologies. At the time of this test, the Civil Engineering Research Foundation (CERF) was the EPA contractor responsible for the EvTEC Program (In 2005, the EPA – CERL agreement to perform this service ended). The EvTEC series of tests on the Plasma Enhanced Melter® (PEM®) (Model G200) were conducted in early 2000. The data were analyzed, peer reviewed, and reported in Dec 2002, which may be viewed or downloaded by clicking EvTEC Report, or may be purchased from the CERF library. An abbreviated paper was published and presented at the IT3 Conference in 2003, which may be viewed or downloaded by clicking IT3 2003 EvTEC Summary Paper. The results of the EvTEC series of tests on hazardous waste demonstrated on a simulated hazardous waste stream that the destruction and removal efficiency (DRE) was at least two orders of magnitude greater than the RCRA DRE requirements for a hazardous waste treatment incinerator. Consequently, the EPA approved the PEM™ for the treatment of hazardous waste, which may be viewed or downloaded by clicking EPA Letter. PCB Testing by Kawasaki Heavy Industries Kawasaki Heavy Industries (KHI) purchased a Model G100 PEM® for PCB destruction in Japan. Prior to being permitted by the Japanese Ministry of the Environment, KHI had to verify that the system met Japanese requirements for destruction efficiency. The G100 was installed and testing was performed in 2003. The Japanese Industrial Waste Management Foundation reviewed the KHI test data and analyzed the results, which may be viewed or downloaded by clicking JIWMF Report in Japanese or JIWMF Report Translation to English (for an English translation). The ultimate result is that the PEM® is now an approved technology for PCB destruction in Japan. The results of the KHI tests have been published and presented at the IT3 Conference in 2004. This paper may be viewed or downloaded by clicking IT3 2004 PCB Paper. Medical Waste and Electronic Scrap Testing The same PEM® facility used for the EvTEC Hazardous Waste Testing (Model G200) was also used for a series of tests on medical waste and electronic scrap. The results of these tests were also reported in the EvTEC Report discussed above. Mercury Capture Testing In 2004, InEnTec performed a test on the efficacy of the mercury capture technology to be implemented on medical waste facilities in the future. This test was conducted on the InEnTec engineering scale PEM® at the Richland, WA, Engineering Center. The testing established the effectiveness of the specialized carbon filter technology, removing mercury to below detection levels. The results of this testing was published and presented at the IT3 Conference in 2005, which may be viewed or downloaded by clicking IT3 2005 Mercury Capture Paper. Medical Waste Alternative Treatment Technology Approvals One of the major market areas InEnTec is pursuing through its subsidiary S4 Energy Solutions LLC is medical waste processing. Most states require that certain portions of the medical waste stream be incinerated. This is typically the pathological materials, pharmaceuticals, and trace chemotherapy materials. In order to qualify to treat these materials, approval as an “alternate to incineration” must be obtained. These approvals have obtained for several states. The states having approved the PEM™ as an alternate technology are as follows (Click on state to download their approval letter): Note, in both Oregon and Michigan, certain portions of the waste stream are required by law to be sent to an incinerator. Since the PEM® is not an incinerator, the state representatives believed that they had no discretionary capacity to approve the PEM® for all waste streams even though the PEM® operates at higher temperatures than do incinerators. Michigan is changing its law to reflect that other systems such as the PEM® can be approved for all wastes. Once the law is changed, the PEM® will be fully approved for all portions of the Michigan medical waste stream. Air Permits and Emissions Testing USA – Allied Technology Group; RCRA / TSCA Permit Allied Technology Group was the first InEnTec customer to obtain a permit to process hazardous waste mixed with radioactive constituents. The permit was issued by the USEPA and the Washington Department of Ecology. Taiwan – Global Plasma Global Plasma undertook a performance test for the Taiwan Environmental Protection Agency (EPA) in early 2006. This system was used to process medical waste and batteries and the syngas generated was used in a dual fueled diesel engine to produce electric power. Global Plasma has received approval to operate under the Taiwan EPA operating permit process. USA – California Air Permit InEnTec Medical Services California, LLC (a subsidiary company of InEnTec) obtained two approvals for a permit-to-construct (Air Permits) for a medical waste treatment facility in Northern California (Tehama County Air Pollution Control District) in July 2005. A California environmentalist activist organization along with a local group organized by the activists filed an appeal to the local Air Pollution Control District citizen based Hearing Board. The appeal basically claimed the local Air Pollution Control District erred in issuing the permits. Due largely to the complex legal and scientific issues involved, the citizen board agreed with the appellants’ positions and the InEnTec permits were withdrawn. InEnTec filed its own appeal of the Hearing Board’s findings in the Tehama County Superior Court because we believed that the Hearing Board failed to correctly interpret the law and incorrectly overturned the permits. On Jan 26, 2007, Tehama County Superior Court, Judge John K. Letton, issued his ruling. Judge Letton, in a detailed 35 page ruling, found all 25 of the Hearing Board’s findings without merit (see Press Release). Judge Letton further required that “The Hearing Board shall give proper notice and hold a further hearing in this matter no later than February 16, 2007. The Board may continue that hearing from time to time, but the Board shall issue its final written decision/order and findings no later than March 2, 2007.” The Hearing Board met on February 16, 2007 and reviewed their previous findings in light of Judge Letton’s ruling and voted to reinstate the permits on a 3 to 0 vote. Judge Letton’s complete ruling may be downloaded here. Following the Hearing Board 3-0 ruling against the appeal of the permits, the activists filed another appeal that claimed the Hearing Board should not have ruled without its fourth member present (he was out of town at the time of the Feb 16, 2007 meeting). This appeal was upheld and the hearing board was required to set aside their earlier decision and review the air permit appeal according to the original instructions given by Judge Letton. The Hearing Board met again on September 10, 2007 and this time ruled 3-1 against the air permit appeal. The local news paper, the Red Bluff Daily News, published an editorial following that latest hearing that may be read or downloaded here. Recycling Determination InEnTec has applied for and obtained approvals from various state agencies for a RCRA recycle determination (40CFR-261). These approvals have numerous regulatory and economic advantages for InEnTec and its customers. The PEM® process recycles feedstock materials into such useful products as clean hydrogen, and alcohols such as methanol and ethanol. Recycle approval requires that the feedstock have a significant hydrocarbon content and, when processed in the PEM® gasification system, produce significant syngas. The syngas may be used directly or further processed into other products. Approval by a state agency is generally done on a case by case basis. |