Thursday, February 23, 2012

Cleveland's waste-to-energy proposal is faulty; new source of pollution, risk of emerging technology; flawed process and doesn't seek to use best practices for waste management

The following is information gleaned from research and documents provided by energy and waste consultants, U. S. EPA and other sources pertaining to reviewing the Cleveland Public Power proposed waste-to-energy facility.  The report attempts to layout and explain the problems with the proposed project and the need to focus on waste source reductions, re-use, composting and recycling, before pursuing expensive and risky waste-to-energy technology.  It is broken into four sub-sections:
  1. Non-standard faulty process and project phasing and development.
  2. Best practices in waste management not being pursued first, project driven by waste-to-energy goal.
  3. Proposed thermal gasification technology and scale is considered emerging, with too many risks and costs that could jeopardize CPP's viability.
  4. Pollution, Environmental Justice issues and need for stronger public education and involvement.
A big thanks to the following organizations as well as the numerous citizens and businesses that have been involved for the last several months in researching and verifying the information enclosed - Environmental Health Watch, Earth Day Coalition, Northeast Ohio Sierra Club, Ohio Citizen Action.  Links to the project doceuments and other sources of information are provided in a previous post here.

Major points of research and concerns about CREG Center

Here are some select excerpts (from 22 pages) that convey the summary:

U.S. EPA states Cleveland waste-to-energy project must be regulated as a major source of pollution; City of Cleveland submits revised plans in attempt to be regulated as minor source of pollution.

U.S. EPA asserts Ohio EPA issued Draft Air Permit in violation of Clean Air Act

In the first of two separate communications today, U.S. EPA sent a letter this morning to the Ohio EPA asserting that the review and processing of the City of Cleveland's permit application for a waste-to-energy facility was done incorrectly by allowing the application to be considered under regulations for a “synthetic minor”, or new minor source of pollution as opposed to more stringent regulations for a new major source.

REF: 2/23/12 U.S. EPA letter (Scribd on-line document or PDF download)

The U.S. EPA cites Section 169(1) of the Clean Air Act and stated in their letter that “Cleveland Public Power falls within the listed source category “municipal incinerators capable of charging more than fifty tons of refuse per day”.

The letter goes on to summarize that the permit application will need to be modified and re-evaluated.  They then provide an extensive list of sixteen additional comments and concerns about the project.

The release of the letter today coincides with the closing of the official public comment period for the Draft Air Permit which was released by the Ohio EPA for the project.

Cleveland Public Power announces scaling back of project and lowering emissions to be regulated as a minor source of pollution

In what appears as a direct response or move based on anticipating the U.S. EPA affirmation today, Cleveland Public Power announced a modification to their plans for the project to lower project air pollution.

The City stated today that they’ll be “reducing the number of gasification lines from 4 to 3, enhancing the proposed air pollution control equipment and increasing the facility’s stack height from 175 feet to 200 feet.”  And, that these enhancements will significantly reduce the maximum annual emissions…by an average of more than 25% and also reduce the predicted maximum air quality impact in the nearby neighborhoods by an average of more than 50%.”

REF: 1) Comments re: Draft Air Permit; 2) Final comments [mark-up] of Draft Air Permit; and, 3) Final emissions & Air Qaulity Impact Comparisons [w/modified emission calculations].

It is unclear by these two separate communications today what the next steps in the process for this project will be.  It is possible that due to today’s U.S. EPA’s assertions the Ohio EPA may be required to re-issue a new draft air permit which would then trigger a new public comment period and process of review.  It would appear that the Cleveland Public Power is attempting to modify their initial application and by reducing the scale of the project, hoping to have the current draft air permit modified and approved with no further public comments or public process.

Meanwhile, Cleveland City Council is still holding a piece of legislation, introduced back on November 4th, 2011 that would authorize between $200,000 and $250,000 to hire a consultant to review a Request for Information and Qualifications that the City issued back in September of 2011.

In terms of the estimated $2.0 million project costs to-date - in addition to the internal project development within Cleveland Public Power and the Division of Waste, there have been three separate trips to Japan to view technology of Kinsei Sangyo Co., Ltd;  there have been multiple feasibility studies that have included a review of the recycling pilot project by R. W. Beck (2008); a feasibility study that looked only at the gasification project proposed by Tien, conducted by RNR Consulting Inc. (2009); and, Peter Tien and his company Princeton Environmental Group were awarded a $1.7 million contract (Scope of Work) to conduct and preliminary design for the facility and to prepare and submit the air permit application.  And, then most recently Cleveland City Council has been asked to approve authorization (Ord. 1574-11) of up to $250,000 for an additional consultant as mentioned above.

UPDATE 2/27/2012 -- The City of Cleveland's Department of Public Utilities issued a contract default  letter to Peter Tien of Princeton Environmental Group that gives him 10 working days to correct deficiencies in his $1.5 million contract for preliminary design and permit application work.

Considering the changes Cleveland Public Power (CPP) has announced today regarding the number of gasifiers/furnaces (they’ve reduced the number from four, two-batch gasifiers (8) and one furnace (4) to three, two-batch gasifiers (6) and one furnace (3); we should expect to receive additional information regarding the amount of waste that is being proposed to be gasified/combusted.  Prior to today’s announcement the amount was approximately 560 tons per day or approximately one-half of the average daily tonnage of waste processed daily by the City.  In addition, we should expect to get updates on potential cost re-calculations and it was anticipated that CPP would be releasing additional information this week on financing operations for the estimated $180 to $300 million project.

Also affected from today’s announcements is likely the amount of power that would be generated from the facility.  The project was initially planned to generate 20 MW of power and then it was downsized to a project 15 MW of power.  It has also been estimated that the facility itself would require 5 MW of power to operate.

Thanks to Congressman Dennis Kucinich for his work in prompting the U.S. EPA's action today as well as the following organizations that have been leading the opposition to the proposed facility as well as the being the major proponents for a more common sense approach to adopting best practices in waste management that create more jobs and are less risky -- Environmental Health Watch, Earth Day Coalition, Northeast Ohio Sierra Club, Ohio Citizen Action, and too all of the residents in the community that have been involved as well!

Congressman Kucinich's Press Conference at Cleveland's Ridge Road Transfer Station, site of the proposed waste-to-energy facility - 2.23.2012