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1. Non-standard faulty process and project phasing and development 2. Best pracCces in waste management not being pursued rst, project driven by waste-to-energy goal 3. Proposed thermal gasicaCon technology and scale is considered emerging, with too many risks and costs that could jeopardize CPPs viability 4. PolluCon, Environmental JusCce issues and need for stronger public educaCon and involvement
B.
C.
D.
CREG
Center
1. Assessment
of
scope,
goals,
systems,
processes,
resources,
technologies
-
INCOMPLETE
[focused
on
alterna3ve
WTE
technologies
with
no
waste
management
assessment]
2. Expert analysis, due diligence, review of best prac3ces, development of op3ons and ac3ons
2. Expert [Internal] analysis, due diligence, review of [WTE] best prac3ces, development of op3ons and ac3ons
3. Seek community support, project components developed assessed and conrmed as feasible
3. Seek community support, project components developed, [internal selec3on of technology and single-source vendor with review by RNR] assessed and conrmed as feasible
4. Compe33ve bidding, project partner development, project components re-assessed, rened, conrmed
5. Begin project implementa3on, [preliminary design] permit applica3on, - BUT - project design, nancing - NOT developed [cost $1.5 million contract with single-source] 3. seek community support [required EPA comment period]
4. Compe33ve bidding, project partner development, project components re-assessed, rened, conrmed [ Narrow RFIQ issued with limited responses intended to quasi-bid gasica3on technology, no new companies responded for gasica3on technology component.]
2. Best practices in waste management not being pursued first, project driven by waste-to-energy goal
A. Need
for
analysis
of
waste
management
best
prac3ces
and
how
to
cost
eec3vely
implement
reduc3on,
reuse
and
recycling
of
waste.
B. Insucient
analysis
done
to
seek
solu3ons
for
mone3zing
and
funding
city-wide,
automated
curbside
recycling.
Cost
es3mated
at
$29
million.
C. Zero
Waste
means
establishing
goals
and
a
plan
to
invest
in
infrastructure,
workforce,
and
local
strategies
to
reduce
waste
at
sources,
re-use
and
recycle
prior
to
seeking
higher
cost
disposal
solu3ons.
Zero
Waste
is
the
most
ecient,
highest
job
producing,
sustainable,
energy-ecient
climate
change
solu3on
to
waste
management.
D. Best
prac3ces
in
the
industry
point
to
variable-rate
fees
and
other
incen3ves
for
residen3al
and
commercial
waste
streams.
E. Residents
perceive
current
at
$8.50
fee
and
other
polices
as
puni3ve
NOTE:
fee
sunsets
in
2013
and
will
require
Councils
re-approval.
4
Solid
Waste
AssociaCon
of
North
America
(SWANA)
Waste
to
Energy
as
a
Part
Integrated
Solid
Waste
Management
Policy
-
The
use
of
waste
to
energy
technology
should
be
consistent
with
the
US
EPAs
current
waste
management
hierarchy
and
local
government
integrated
solid
waste
management
plans,
that
include
exisCng
and
planned
waste
prevenCon,
waste
reducCon
and
recycling
programs.
Permijng
of
waste
to
energy
facili3es
should
be
consistent
with
the
established
long
term
needs
of
local
government
and
their
integrated
solid
waste
management
plans
hkp://epa.gov/climatechange/wycd/waste/downloads/overview.pdf
REF:
SWANA
TECHNICAL
POLICY
T-8,
1/12/2012
hkp://swana.org/Portals/TechnicalPolicies/T-8_WTE_PR.pdf
hierarchy
places
emphasis
on
reducing,
reusing,
and
recycling
the
majority
of
wastes.
[1]
Reducing
MSW
genera3onmost
eec3ve
[4]
Capturing
the
material
valuethrough
recycling
should
be
considered
next.
[5
&
6]
CombusCon
or
gasicaCon
with
energy
recovery,
or
WTE,
is
the
environmentally
preferable
route
for
mixed
solid
wastes
that
are
neither
recyclable
nor
compostable.
on
environmental
and
economic
factors.
[7]
Landlling
MSW
is
the
least
preferred
op3on.
However,
community
decisions
are
based
both
hkp://www.epa.gov/osw/nonhaz/municipal/wte/nonhaz.htm
hkp://green3e.naem.org/tag/waste-management-strategies
3. Proposed gasification technology and scale of project has too many risks and costs and could jeopardize CPPs viability
A. Gasica3on
technologies
for
processing
MSW
are
considered
emerging
and
have
not
been
proved
at
the
scale
being
proposed.
B. There
are
currently
no
commercial-scale,
MSW
gasica3on
systems
opera3ng
in
the
US.
There
are
fewer
than
20
in
the
world,
all
appear
to
be
using
more
homogeneous
feed
stocks
and
none
are
designed
for
more
than
70
to
100
tons
per
day
(TPD)
throughput.
Most
are
rela3vely
small,
i.e.,
>10
TPD.
C. City
funds
commiked
so
far
approach
$2
million
with
another
$250,000
pending
for
hiring
consultant
to
review
responses
to
Request
For
Informa3on
&
Qualica3on
focused
on
gasica3on.
D. Detailed
nancing
op3ons
have
not
been
evaluated;
likely
use
of
high-cost,
long-term
power
contract
for
technology
that
cannot
be
considered
reliable;
cost
of
facility
is
est.
at
$180-$300
million.
7
Waste-to-Energy and Conversion Technologies under the Commercial Microscope Including Projects Currently Under Development Presented via Waste Conversion Congress West Coast, December 6th, 2011 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
10
Waste-to-Energy and Conversion Technologies under the Commercial Microscope Including Projects Currently Under Development Presented via Waste Conversion Congress West Coast, December 6th, 2011 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
11
Waste-to-Energy and Conversion Technologies under the Commercial Microscope Including Projects Currently Under Development Presented via Waste Conversion Congress West Coast, December 6th, 2011 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
12
SWANA North Carolina Chapter Conference 2008 August 27, 2008 - Alterna3ve Technologies to Landlls or: The Resurgence of Waste-To-Energy (WTE) and Conversion Technologies (CT)and Dont Forget More Recycling Too! By Harvey Gershman, Gershman, Brickner & Brakon, Inc. hkp://www.gbbinc.com/speaker/wte.pdf
13
4. 5.
purchase from City of Edmonton, pre-sorted MSW, 100,000 tons per year. NOTE: Result of several years of
research and over 6,000 hours of tes3ng and valida3on, at Enerkem's pilot and commercial demonstra3on facili3es in Quebec. 14
December 2011 news arCcle ciCng Peter Teins (PEG) esCmate with nancing:
hes
negoCated
a
$300
million
nancing
package
if
the
city
chooses
a
Kinsei
plant.
16
The Mysterious Mister Tien; The man who sold Cleveland on visions of prosperity isn't all he claims to be by Maude L. Campbell, December 7th, 2011, hkp://www.clevescene.com/cleveland/the-mysterious-mister-3en/Content?oid=2772517
REF: RNR Study, 2009, 6.3.2 General Issues, Table 7. Capital and O&M Costs for MSWE Facili3es
[Regarding feedstock]: PEG assumed the hea3ng value of the feedstock (pellets) at 10,000 BTU/lb with a
moisture
content
of
less
than
10%.
These
fuel
pellets
consCtute
only
part
of
the
gasicaCon
feedstock.
In
its
latest
submikal,
PEG
men3oned
that
major
haulers
could
supply
addiConal
high
BTU
industrial
and
commercial
waste
such
as
scrap
Cres
and
auto
uWithout
detailed
calcula3ons
using
real
data
from
an
exis3ng
facility,
it
is
dicult
to
rely
on
these
numbers.
Thermal
conversion,
such
as
using
gasica3on
technology
to
process
MSW,
is
a
new
and
innova3ve
technology
that
is
only
in
commercial
opera3on
overseas.
PEGs
proposed
facility
is
in
the
concept
stage.
[Note:
Research
thus
far
shows
no
evidence
of
an
operaConal
thermal
gasicaCon
waste-to-energy
facility
of
comparable
scale
that
is
using
solely
MSW.
Any
comparable
size
facility
in
operaCon
or
being
planned
appear
to
use
a
more
homogeneous
(i.e.,
wood
or
Cre
bio-mass
etc)
or
an
added
percentage
of
homogeneous
feedstock
with
higher
BTU/lb
raCngs
that
are
used
to
increase
total
feedstock
energy
capacity.
17
Review
of
Citys
Request
for
InformaCon
&
QualicaCons
Kinsei
Sangyos
response
provides
informa3on
on
approximately
100
opera3ng
and
commercial
facili3es
with
capaci3es
of
between
1
-
60
tons
per
day.
They
note
a
total
of
260
systems
in
opera3on.
Their
reference
technology
is
a
35
ton
per
day,
MSW
to
steam
facility
in
Hoengseong-Gun,
Korea
that
opened
in
November,
2005.
Addi3onal
reference
facili3es
include
three
40,
24,
and
12
tons
per
day
facili3es,
all
using
industrial
solid
waste
to
ash
being
in
opera3ons
since
2003,
2006
and
2011
respec3vely.
18
Company
Project Developers
Consultants
Alternative Resources, Inc. ARCADIS-Malcolm Pirnie Cleveland Thermal Compact Cooling Solutions DLZ Dongara Pellet Plant LP & Remasco Envision Waste Services Gershman, Brickner & Bratton, Inc. (GBB) HDR Engineering, Inc. (HDR) Indiana Recycling and Renewable Fuels Kinsei Sangyo Middough Municipal and Financial Services Group Ralph Tyler Companies SAIC Energy, Environment & Infrastructure, LLC (SAIC) Wells Fargo Securities WSI Management Inc.
19
4. PolluCon,
Environmental
JusCce
issues
and
need
for
stronger
public
educaCon
and
involvement
A. Industry
experts
warn
about
opposiCon
by
environmentalist
and
the
public
regarding
rst
demonstraCng
high
recycling
percentages
and
concern
for
emissions.
Coming
under
EPA
regula3ons
doesnt
eliminate
the
need
for
public
buy-in
early
on
in
the
projects
development.
Emissions
include
500
lbs
of
lead,
260
lbs
of
mercury
and
79
tons
of
par3culate
PM(F+C)
per
year.
B. Though
presented
as
a
clean
source
of
energy,
gasica3on
produces
the
same
pollutants
as
standard
incinerators.
The
facility
would
be
the
largest
emiter
of
mercury,
would
increase
lead
air
emissions
up
to
63%
and
would
be
one
of
the
biggest
regional
soot
emiters.
All
incinera3on,
including
gasica3on,
wastes
the
energy
and
resources
in
municipal
solid
waste.
C. Environmental
Jus3ce
concerns
include
those
who
live
closest
will
be
impacted
by
emissions;
pollutants
can
be
carried
long
distances
and
can
persist
in
the
environment
for
decades;
no
air
modeling
provided
since
requests
made
in
December.
Comments
close
2/23.
20
Emission information developed from CPP public information and permit application showing the application amounts at 92% use and the Ohio EPAs limits of use at 72%:
Air Modeling:
Project team has not yet responded to requests for air modeling data that could be understood by the public. This data was requested in December 2011. It is likely this informa3on will not be made available prior to EPA Public Comment period being closed. This informaCon would provide details of emission levels and esCmaCons of direcCons and distances traveled.
21
State
and
Regional
PolluCon
rankings
&
Emission
informaCon
Mercury
and
ParCculate
Mater
Ohio
ranks
worst
in
the
country
for
toxic
air
polluCon.
The
American
Lung
Associa3ons
State
of
the
Air
2011
report
gives
Cuyahoga
County
a
failing
grade
for
ozone
and
parCculate
polluCon
levels.
The
eight-county
Cleveland
metropolitan
area
is
ranked as having the naCons 12th highest level of year-round parCculate polluCon.
22