Comments on draft permit Facility ID: 0250110024
Permit Number: P0132799
VIEW more public comments here August 24th, 2023 Erik Bewley Ohio EPA DAPC Northeast District Office 2110 East Aurora Rd. Twinsburg, OH 44087 Dear Mr. Bewley, I wish to register comments related to the draft air pollution permit-to-install and operate initial installation P0132799, namely, the SOBE Thermal Systems proposal to install a 13.72 MMBtu/hr Thermolyzer® pyrolysis unit on North Avenue in Youngstown, OH, for the purpose of combusting natural gas and incinerating automotive tire chips to generate thermal energy. A lot of details are left out of the description of how the Thermolyze ® will work, but it does mention the intent to incinerate 88 tons per day of tire chips. I estimate that will be 4 fully loaded tractor trailers of tire chips coming in each day. I understand that most of the steel content of the tires will have been removed prior to arrival. Why whole tires are considered solid waste, while cutting them down to 1-3” pieces before pyrolysis is not, is a mystery to me, but that’s what the federal regulations state. I realize that this permit is largely concerned with emissions into the air, but is any agency looking at the solid waste flow? The plant description claims that carbon black and carbon steel are the byproducts of the process. It’s much more complicated than that. Pyrolyzed tire chips commonly leave behind 30-35% of the original weight in char that contains mostly carbon, but also has significant amounts of ash, zinc, and sulfur. Thus the 88 tons per day going into the plant will have around 30 tons of black crud to be carted away each day. I have heard SOBE personnel imply that their gas cleaning units will somehow shift convert all of the carbon into combustible syngas, but where is the ash going? Where is the zinc going? Where is the sulfur going? Zinc is a special case when it comes to tires. I have seen EPA reports where it considers incinerating tires in a designed combustion chamber to have the same polluting impact as regular fossil fuels, with the exception of the zinc oxide content, which is added to tires as a vulcanization promoter at about the 2% level. Its volatility is measurable but minimal, so we can expect the plant to generate a solid waste stream of about 1.75 tons of ZnO per day, or 640 tons per year, mixed in with the other solid residues. Even so, I’m more concerned about the sulfur, as it could very well exit the plant as gaseous SO2. Once again, I don’t know how the gas cleaning units operate, but I do know that tires contain about 1.6% sulfur by weight. The SOBE plant will thus have over 500 tons of sulfur per year going into it, and according to the applicant, less than 1.0 ton will come out? In one study, using a conical bed reactor at 575 °C, the char was 35% of the total mass entering the pyrolyzer. The char analysis for sulfur came to 3.68%, a not inconsequential amount; nevertheless, that only accounted for 60% of the total sulfur. Where did the rest of it go?
You can email your comments & questions DIRECTLY
to Erik Bewley of the Ohio EPA: DAPCNE.comments@epa.ohio.gov [Erik Bewley]
or use the form to send instantly at:
Comment to OEPA (goes to same email address of Ohio Environmental Protection Agency)
2) Send comments & questions via postcards and letters to: (must be received by EPA by Sept. 10, 2023.)
Ohio EPA
Andrew Hall
Permit Review/Development Section
Ohio EPA, DAPC
50 West Town Street Suite 700
PO Box 1049
Columbus, Ohio 43216-1049
and
Ohio EPA DAPC, Northeast District Office
2110 East Aurora Rd.
Twinsburg, OH 44087
IMP! include these ID #'s in your Comments:
RE: Facility ID: 0250110024
Permit Number: P0132799
