Technical Review Document on FibroMinn's Petition for a Non-Waste Determination Pursuant to 40 CFR 241.3(c)

This document outlines the criteria that Benson Power, LLC poultry litter meets to qualify as a non-waste fuel. This technical review document outlines the following information:  

  • how the material has not been discarded in the first instance
  • how it meets the three legitimacy criteria outlined in the NHSM rule
  • how it meets the five additional factors outlined in the NHSM rule
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