From: BARROWS Bob
Sent: Thu Nov 29 15:24:59 2012
To: BARROWS Bob; FULLER Brian; LUMPER Bruce; NUTTALL Christie; PICKERELL Loretta; RAWSON Stephanie; RHOADES Cathie; ROICK Tom; SPENDELOW Peter H; VANDEHEY Maggie
Subject: FW: Conversion Technology Comments
Importance: Normal
Hi all,
Here’s the second of two Mary Sue comments. bb
Bob Barrows | Waste Policy Coordinator
Dept. of Environmental Quality
165 E. 7th Ave., Eugene, OR 97401 | barrows.bob@deq.state.or.us
( 541.687.7354 | 800.844.8467 x7354 (in Oregon)
From: Mary Sue [mailto:duckyrecycler@verizon.net]
Sent: Thursday, November 29, 2012 3:13 PM
To: BARROWS Bob
Cc: 'Stern, Matthew'
Subject: FW: Conversion Technology Comments
Oops, I left off the end of the second to last statement. I would like to see the residual exemption increased from 10% to 20%. This may help us deal with MRF plastic more effectively.
From: Mary Sue [mailto:duckyrecycler@verizon.net]
Sent: Thursday, November 29, 2012 3:09 PM
To: 'barrows.bob@deq.state.or.us'
Cc: 'Stern, Matthew'
Subject: Conversion Technology Comments
Hi Bob, I have finally had some time to go through the CT Documents and I do have some comments and concerns.
#1. 340-93-0050 (3)(d)(E) I absolutely object to the inclusion of the word "non-recyclable" before plastic. Non-recyclable is not defined in this rule. Who is going to decide what is and isn't recyclable? This is a deal breaker for me. For example, we recently received some bags that were laminated with two different plastic resins together. We were offered 2 cents per pound by an export customer. The bags however cost us 2 cents to pick up and 8 cents to bale for a net loss of 8 cents. These are the perfect material for oil. But if I am excluded from using them as a feedstock or they cause our MRF to lose our permit exemption because we have a "positive" sales price for the bags then I can't go along with this definition. I do not think it is appropriate for staff at DEQ who have no market experience making a decision on what I can and can not use for a feedstock. I have no problem feedstock like PVC that has environmental emission risks being excluded from our feedstock, but I do have a problem with someone directing our sales and marketing.
#2. 340-93-0050 (3)(d)(B). I would like to have the clause "or material separated at a MRF" added to the sentence. As we discussed during the committee meetings, we believe that materials separated at a MRF are no longer useless and discarded and should lose the designation as solid waste. The AG that spoke at the committee meeting was not clear on this interpretation. If I remember right he pointed back to DEQ's interpretation. I still would like to have a more definitive interpretation by the AG's office.
#3. The following items now appear in draft rule but were never discussed in committee:
a. Reference to autoshredder fluff in the performance standards. Why is it called out and eliminated? We don't plan to accept it but I know Agilyx has had discussions with an autoshredder fluff supplier.
b. We never discussed whether or not a CT Facility could charge a tip fee. Why can’t they? We don't think that would be the case but why exclude it? Who decided?
c. Where did the Haz Waste language in the Op Plan come from? We didn't disuss it to this degree.
Finally, I know we agreed on a 10% residual figure for the plastic to oil facility exemption, but
Now since some of these are significant concerns, how do we proceed? I'm not inclined to support the rules as they are currently drafted without more discussion and in the case of my primary concern without the elimination of language.
Mary Sue Gilliland
Vice President Operations and Business Development
Agri-Plas, Inc.
503-390-2381