Memo's from PEAT
(Revised 9Feb99 at 20:21)

MEMO 1 - from Marlin D. Springer, Ph.D., President of PEAT, inc.

PEAT's position regarding the proposed Medical Waste Incinerator (and non-incinerator) Regulations.

PEAT claims to have technologies that are not traditional incineration.

PEAT's thermal waste treatment technology is based on Plasma Energy, supplied by Plasma Torches. There are several companies that use plasma torches to enhance the combustion process, but their process is still clearly incineration. Just the use of plasma torches clearly does not justify a claim of non-incineration. PEAT's claim that we do not belong to the "Incineration Family" is based not on the fact that we use plasma torches, but on the fact that our method and process of destroying various wastes is not combustion.

During FDA meetings last summer with several companies that wanted to be recognized as non-incinerators, it was obvious to me that the collection of technologies in that group was too diverse to fit comfortably under a common regulation. Some of them could be described as; "Incineration with a Twist", "Staged Incineration with Improved Controls", and "Enhanced Incineration". Other members of the group claimed "exemptions from the laws of physics", and we still do not understand how some of the others worked.

The bottom line is that there are numerous technologies that would like to get out from under the classification of "Incinerators". There are two main reasons for this. I) There are States where Incinerators are banned, and being classified as an incinerator prohibits even consideration for permitting, and 2) There is a general public perception that "All Incinerators are bad", with eager politicians who promise "No New Incinerators"!

In a perfect world, we would have preferred that the US EPA evaluate PEAT's technology (as California and Alabama have done, and as Washington, Texas, New Mexico, New York and HI's project in Indianapolis, Indiana are doing), and reach the same conclusions, provide official recognition of our technology as "Non Incineration", with requirement that we be held to the same air emission standards as Incinerators. However, we realize that this is not a "Perfect "World". In a "less than perfect world", PEAT would welcome some US EPA recognition, through definitions of incineration and pyrolysis that would distinguish us from incinerators, and allow the individual States to determine which regulations/standards are appropriate.


 INCINERATION vs. PYROLYSIS

Incineration has fallen in disfavor in recent years, and in some states has been banned or placed under a moratorium for certain applications. PEAT has developed a Thermal Destruction and Recovery (TDR) system and process (HI's PBPV System) that by definition is not incineration. It achieves near-total destruction of simple and complex organic materials, and does so without heat from a combustion process.

Whether the process is called "incineration" or not is not an issue as far as meeting air and water emission requirements. The new Air Toxics Program (Federal and most States) requires permits from all processes that potentially emit any of the 189 pollutants on the air Toxics list. Being recognized as not-an-incinerator becomes an issue only when a state with bans or moratoriums on incinerators cannot accept an application for a permit to construct and operate, and in how the public perceives the technology.


 INCINERATOR ("To Be" or "Not To Be")

The position that PEAT's TDR process (HI's PBPV System) is not incineration, is based on two premises. 1) the process in the chamber that destroys the waste does not fit the definition of combustion, but is instead, pyrolysis. 2) the products of pyrolysis (hydrogen, carbon and carbon monoxide) are different from the products of combustion (carbon dioxide and water) and offers options for chemical energy recovery that combustion and incineration do not.

These premises are supported by the following definitions.


Incinerate = Burn = Combust (See Webster or equivalent)

  • Combustion = A chemical process (as an oxidation) accompanied by the evolution of heat and light


  • Products of Combustion of Hvdrocarbons = Carbon Dioxide and Water


  • Pyrolysis = Chemical change brought about by heat


  • Products of Pyrolysis of Hydrocarbons = Hydrogen, Carbon and Carbon monoxide

Within the TDR processing vessel where the waste is fed and destroyed, combustion is not occurring. The waste is destroyed by pyrolysis, and the heat that causes the pyrolysis has been provided by an electric arc (not combustion).

It can be argued that PEAT's TDR system is similar to starved air combustion systems, where waste is only partially combusted in the primary chamber, producing a combustible gas that is then fully combusted in an afterburner. There is a significant difference here in that PEAT's TDR system does not employ an afterburner. The combustible gas (pyrolysis gas) produced by the TDR is then cooled and scrubbed, resulting in a syngas that can be combusted, or can be used in other energy recovery systems.

Cited as "evidence" that the PEAT's TDR process is incineration, certain individuals have referenced a paper written by Clyde R. Dempsey and E Timothy Oppelt of the Risk Reduction Engineering Laboratory, US. Environmental Protection Agency, Cincinnati, Ohio, entitled; "Incineration of Hazardous Waste: A Critical Review Update", that was published in the January, 1993 issue of Air and Waste. In this article, the authors define "Incineration Practice" as it applies to hazardous waste. They state that "Incineration is an engineered process that employs thermal decomposition via thermal oxidation at high temperature (usually 900 degrees C or greater) to destroy the organic fraction of the waste and reduce volume". To those who interpret this as including the PEAT TDR pyrolysis process we direct their attention to the words "...thermal decomposition via thermal oxidation...". Thermal oxidation is heat derived from oxidation of organic materials (C + 02 ----> C02) and (H2 + 0 ----> H20) which means Combustion. PEAT's TDR process employs thermal decomposition via A Plasma Torch, not combustion.

The authors continue with examples of "incineration" of hazardous, waste, and discuss the "incineration" of contaminated water and the "incineration" of contaminated soils. Certainly, anyone who understands basic science would agree that the water and the soil were not incinerated - they simply won't burn. A look at the references they cite will reveal that an auxiliary filel is combusted, with excess air, to raise the temperature of the water or soil to a level that volatilizes the hazardous contaminant and with sufficient excess air, the hazardous contaminant combusts as well. What the authors are attempting to do is define the engineering process, that has as its primary activity, thermal decomposition via thermal oxidation. PEAT's TDR accomplishes thermal decomposition via plasma energy.

Note: See further description of the incineration process and drawings on page 34 and 35 of the above article.

The argument can be made here that because the TDR process may employ a flare (or thermal oxidizer) to combust the fuel gas, it accomplishes the same end result as an incinerator. This is correct, however, here a second significant difference must be taken into consideration. With the TDR system, combustion of the fuel gas in the flare, or thermal oxidizer, is one of several choices that can be made for energy recovery from the process. Other choices for consideration include extracting the hydrogen gas as an alternative fuel, powering a fuel cell for electric power generation, or powering a gas turbine or an internal combustion engine for electric power generation. An incinerator can not offer any of these options.

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