White Paper on Waste Processing Technologies - highlights of risks associated with GASIFICATION as an emerging technology

REF:

Meeting the Future: Evaluating the Potential of Waste

Processing Technologies to Contribute to the Solid

Waste Authority’s System

Solid Waste Authority of Palm Beach County, Florida

http://www.swa.org/pdf/SWAPBC_White_Paper_9-2-09.pdf

Prepared by:

Gershman, Brickner & Bratton, Inc. 

8550 Arlington Blvd, Suite 304

Fairfax, VA  22031

September 2, 2009

Found an interesting and what appears to be a very useful report (Sept. 2009) that reviews waste management technology for the Palm Beach County FL. 
Even though the information from this white paper was developed over 2-years ago, it marks the same time that Ivan Henderson, Commissioner of CPP lead the trip to Asia to explore emerging technologies (Aug. 2009).  Some of the information may have become slightly outdated, but nonetheless, the most interesting factoids and statements are presented below:

(See further excerpts and references to useful PowerPoint slides here)

Note: CPP has yet to explain how this project, that has been estimated to cost between $180 and $300 million, will be financed.

----------------------------------------------------

Gasification Facilities in operation worldwide:  Seven (7) plants with this technology are currently operating in Japan, with at least two of them firing MSW.  The largest of these plants in Kurashibi has a reported furnace size of 185 TPD, with three units of this size.  Their largest facility fires up to 555 (Metric) TPD of MSW.  There are 20 smaller facilities in Europe and Asia.  Most of them are relatively small (less than 10 tons per day), with none designed for more than 70 tons per day throughput. Since 1996, no new greenfield commercial plant has been implemented.

Reliability: Pyrolysis and gasification systems have limited MSW operating history on which to rely and, although they may have fewer moving parts and appear to be simpler in operation than other systems, they do not have sufficient experience to draw conclusions for reliability of operation.  

Environmental/Air: Several gasification/pyrolysis systems show the gas generated driving a  gas turbine, which could be part of a combined cycle system.  This would increase efficiency; however,
turbine manufacturers are reluctant to guarantee performance on units fueled by syngas  from MSW.

Costs and Revenue Streams: The only technologies with dependable estimates for capital and operating costs, based on long experience in the  U.S., are the proven mass-burn/waterwall, mass-burn/modular and RDF/dedicated boiler technologies. All of the others have cost estimates that are speculative, theoretical, or market driven.  Unless a vendor’s cost proposals are backed by substantial guarantees of performance, they cannot be considered reliable.  

Conclusions: …

3. [in assessing the use of emerging technologies]...[including] gasification without on-site energy production.  If…[Cleveland] pursues the use of these technologies, it must be prepared to manage the considerable risks involved, including commercialization risks, scale-up risks, performance risks, construction and operating cost risks and environmental compliance risks.

4. Accessing these technologies is best done through a competitive public procurement and negotiation process that requests proposals from contractors that are able to provide a facility and services with appropriate financial guarantees to deliver the permitting, design, construction, start-up and acceptance testing, and long-term commercial operations under performance-based full-service contracting arrangements. 

Sources of Information regarding the City of Cleveland CREG Center Proposal

Here are the major sources of information available on-line pertaining to the project:

UPDATED Friday, 1/20/2012

NOTE that the Ohio EPA has confirmed the extension of the Public Comment Period for the Draft Air Permit to the close-of-business, Thursday, February 23rd, 2012.

Send comments to the Cleveland Division of Air Quality, 75 Erieview Plaza, Suite 200, Cleveland, OH, 44114, Attn: David Hearne. CPP Ridge Road Permit #PO107767; Facility ID 1318008750.  Comments sent by email to: DHearne@city.cleveland.oh.us

Three additional meetings will be held by the City of Cleveland to Explain the proposed CREG Center and to take questions and comments from the public (see schedule below), and an additional meeting is being considered specifically for the Hispanic Community.

• Thursday, January 26th @ Zelma George Recreation Center,
  3155 MLK Jr Blvd., 6:00 -9:00 p.m.
• Wednesday, February 8th – Cudell Recreation Center,
  10013 Detroit Ave., 6:00 -9:00 p.m.
• Thursday, February 9th – Harvard Community Services Center,
  18240 Harvard Ave., 6:00 -9:00 p.m.

Information and resources:

• CPP PowerPoint Presentation for Public Meeting held Thursday 1/19/2012  
• Cleveland Public Power (CPP) CREG Center site
• Princeton Environmental Group, Basis of Design Report, 08-31-2011
• CPP Air Permit Application
• EPA Draft Air Permit for proposed project
• Initial EPA Public Hearing Notice for Jan. 9th 2012 Public Hearing, NOTE: City of Cleveland has requested Ohio EPA to extend Public Comment period an additional 30-days to February 23rd, 2012. (Spanish version)
• City of Cleveland MSWE Development Chronology of Events
• Earth Day Coalition Clean Air site
• Ohio Citizen Action Cleveland Incinerator site
• Estimated maximum emissions as stated in the CPP application for air permit operating at 72.24% heat input
• Max Mercury Emissions CPP Facility vs Actual Reported Mercury Emissionsfrom Operating Power Plants 2010
• Max Potential Total PM (F+C) Emissions CPP Facility vs. Actual Total PM Emissions from Major Industrial and Utility Sources 2009
• Feasibility Assessment Report MSW EPF, RNR Consulting, 2009 (cost of $329k)
• Research on Gasification - Excerpts from work conducted by Gershman, Brickner & Bratton, Inc. pertaining to energy technologies. 
• Public Comment submitted by Claude Lawrence Cornett, Jr.

CPP Announces meeting on gasification facility, provides no meaningful data on emissions

NOTICE -- Cleveland Public Power has announced a meeting to be held regarding the proposed Gasification-Municipal Solid Waste-to Energy facility being proposed for the Ridge Road Transfer Station.  The meeting is scheduled to be held at the Estabrook Recreation Center, 4125 Fulton Road, at 6:00 pm, Thursday, January 23rd, 2012.

See the initial Public Hearing Announcement from the EPA for the one and only Public Comment Hearing held on January 9th.  NOTE that the City of Cleveland has requested from Ohio EPA a 30-day extension of the Official Public Comment Period from January to February 23rd.  See the original announcement for where and how to submit comment.

The CPP statement, linked here, see specific text regarding emissions, is an insult to the process.  CPP has applied for an Air Permit to operate a gasification facility.  I find it incredulous that while their Draft Air Permit is being reviewed for public comment (closing 2/2012), that CPP cannot communicate clearly what the emissions are estimated to be; what they’ve actually stated within their permit application.

Instead, under no less a heading of “ Understanding the impact”, CPP states

“...if we don’t allow mercury and other toxins into the gasification process, we will not have mercury and other toxins coming out of the gasification process.”

In fact, here is a listing of the emissions listed for the facility, per CPP’s  EPA Permit Application using a 72.24% utilization of heat input:

1. Particulate PM(F+C) 78.75 Tons per year
2. Sulfur Dioxide (SO2); 78.75 Tons per year
3. Nitric oxide & nitrogen dioxide NOx; 194.31 Tons per year
4. Carbon monoxide (CO); 87.95 Tons per year
5. Volatile organic compounds (VOC ); 26.59 Tons per year
6. Hyposulfurous acid (H2SO2); 7.36 Tons per year
7. Lead (Pb); 500 Pounds per year
8. Ammonia; 16.36 Tons per year
9. Hydrogen chloride (HCI); 6.55 Tons per year
10. Dioxin; 1.27 E-5 Tons per year
11. Cadmium (Cd); 26 Pounds per year
12. Mercury (Hg); 260 Pounds per year
13. Hydrogen fluoride (HF) 1,260 Pounds per year

REF: http://ohiocitizen.org/?p=10745

Let's have a serious discussion of the impacts of these emissions on the people living in our Cleveland neighborhoods and not greenwash this project as panacea to our waste management and energy generation challenges.

As the Council representative of Ward 14, I represent a population of approximately 24,000 people for which our neighborhoods are directly down-wind from the proposed facility, 2 miles North.  The neighborhoods are recognized as low-income and are made up of a population that is between 30% and 44% Hispanic minority.

It is important to note that in consulting with representatives from the EPA Region 5 Office, they have confirmed that the communities to be impacted by the proposed project qualify as Environmental Justice areas of concern, due to the prevalence of low-income and minority (Hispanic) residents who are disproportionately impacted by asthma and other debilitating health conditions related to poor air quality in the City at present.

REF:
     See references to Environmental Justice in “Public Involvement Policy of the U.S. Environmental Protection Agency May 2003” and “Environmental Justice in EPA Permitting: Reducing Pollution in High-Risk Communities is Integral to Agency’s Mission. December 2001”.
     “…while incidence of asthma is average for Hispanics in general, Puerto Ricans are about…as likely to be diagnosed with asthma than non-Hispanic whites, and about 1 in 5 Puerto Rican children are diagnosed with asthma, compared to 1 in 10 Hispanic children overall, and 1 in 13 non-Hispanic White children…” ("Profiles of Latino Health," 2009). 2011 Latino Community Report, Ohio Commission on Hispanic/Latino Affairs.