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EPA Clean Air Act Pyrolysis and Gasification Unit Regulation


On September 8, 2021, the United States Environmental Protection Agency (EPA) issued a Notice of Proposed Regulatory Notice (“ANPRM Notice”) regarding possible future regulation of pyrolysis and gasification units under the Clean Air Act. (CAA) federal.

Pyrolysis and gasification can foster a “circular economy” for plastics, where post-consumer plastic products can be recycled to produce plastic of equal or similar quality rather than being thrown away. Pyrolysis and gasification can convert solid or semi-solid raw materials into useful products such as energy, fuels and chemicals.

Potentially regulated entities include manufacturers of the following products: wood, pulp, paper, cardboard, furniture, chemicals and related products, plastic and rubber products, cement, non-metallic mineral products, and fishing operations. Other regulated entities include solid waste combustion units breaking down municipal solid waste, oil and gas exploration operations, mining operators, pipeline operators, utility providers, private hospitals and healthcare facilities. , including commercial research companies and commercial waste disposal companies.

Many existing operations that incorporate pyrolysis and gasification have been regulated by the EPA under Section 129 of the CAA, which imposes certain emission guidelines and performance standards for different types of solid waste incinerators. . But pyrolysis and gasification have been inconsistently defined and managed under existing Section 129 rules. Therefore, the EPA issued its ANPRM advisory because it believes that “there is considerable confusion in the community. regulated concerning the applicability of section 129 of the CAA to pyrolysis and gasification units ”.

The EPA has set November 8, 2021 as the deadline for submitting public comments. Since the ANPRM notice could lead to new rules for pyrolysis and gasification units as well as changes to the current and existing section 129 rules, industries that use pyrolysis or gasification should consider submit comments to the EPA by the deadline.

© 2021 Greenberg Traurig, LLP. All rights reserved. Revue nationale de droit, volume XI, number 272