Re: GAS-L: Small Scale gasification

[LINVENT@aol.com]

Dear Gasification list,
    The EPA has published proposed regulations exempting gasifiers used at 
refineries from RCRA for power generation. This has very dramatic impacts for 
the field of gasification because of the language which is stated in the 
regulations which includes statements like "gasifiers are not an emission 
source" which means that it separates the technology from incineration which 
is a source. Other statements clearly define gasification as a preferred 
manner of waste or energy source. 
    In our discussions with the EPA, they state that if the gasifier is not 
located at a refinery and operated on the narrow range of feedstock, it will 
be considered to be an incinerator. This is not only a problem with the 
technical issues, but becomes a regulatory and registration or permitting 
problem as the conventional monitoring of incinerator performance cannot be 
done on gasifiers.  
    Any gasifier operator is faced with a possible problem with permitting or 
operational approval. 
    Thermogenics may be forced into a suit to clarify this issue. How can a 
gasifier be a gasifier only for one application? It appears as though the EPA 
is being rather intransigent about this issue. 
    If you are interested in supporting the future of gasification, you may 
wish to assist in this effort. At this point, the discussions are preliminary 
with the EPA, and no legal action on their part has been taken, but we are 
being cautious about this issue. 
    Let us know your thoughts on this. We have a copy of the proposed 
regulations exempting the refineries but cannot provide a URL as we cannot 
find them on the EPA site. 


Sincerely,
Leland T. Taylor
 President
 Thermogenics Inc. 
7100-2nd St. NW, Albuquerque, New Mexico 87107 
phone 505-761-5633 fax 505-341-0424
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