THE CLEVELAND GASIFIER SCAM
We are all gasifiers. Passing gas demonstrates the process. However, we are much more than gasifiers, and so are the proposed Ridge Road “gasifiers.” The proposed Kinsei Sangyo “gasifiers” are incinerators with energy recovery.
The patents for the proposed Kinsei Sangyo thermal municipal waste treatment process correctly call it incineration or incinerator http://www.patentmaps.com/assignee/Kinsei_Sangyo_1.html. Kinsei Sangyo correctly calls itself an “Energy Incineration Plant Company” http://www.kinsei-s.co.jp/index2.htm, although they recently updated their English language web pages describing their specific processes to minimize the use of the term incineration and to use the term gasification.
The eight proposed Kinsei batch dry distillation furnaces would burn municipal waste to ash from the bottom up under smoldering, oxygen starved combustion. The resulting aerosols and flammable gas are then burned in energy recovery furnaces, except for that which may be deposited within and perhaps clog the process, captured and treated by pollution control equipment, or discharged into the environment. Clearly, this is a form of incineration with energy recovery.
This combustion process is classified by US EPA as controlled-air incineration, also known as starved air incineration or two-stage incineration www.epa.gov/ttnchie1/ap42/ch02/final/c02s03.pdf. The emission factors used in the proposed air pollution permit reflect that classification.
Cleveland Public Power, the Cleveland Division of Air Quality, and others have been tricked by Kinsei Sangyo and their representatives to think that the proposed at the Ridge Road waste treatment plant will use gasifiers that are not solid waste incinerators with energy recovery.
As a result, Cleveland Public Power has denied that the proposed thermal treatment process is incineration at public hearings and elsewhere. In addition, Ohio EPA’s air-pollution control staff mistakenly determined that the planned facility is a gasifier rather than an incinerator; and, therefore, thought that the Solid Waste Rules do not apply; and no Solid Waste Permitting is necessary.
The Ohio rules for a solid waste incinerator or solid waste energy recovery facility permit to install application http://codes.ohio.gov/oac/3745-27-50 require, among other things, the submission of:
· Detailed engineering plans,
· To scale layout and cross section drawings,
· Contingency plans,
· A final closure plan,
· Measures to control fires, and
· Other information
The submissions must be in enough detail for a technical review that would assure that the facility is designed and operated in accordance with applicable requirements. This information was not submitted when Cleveland Public Power applied for a permit to install. Those submissions demonstrate that the draft permit to install is based on vague, generic block diagrams of the proposed installation, unsupported performance specifications, and minimal regulatory requirements for emissions from small, conventional incinerators.
Because of the misleading characterization of the proposed thermal treatment process:
· The permit to install application and the draft permit (P0107767) should be withdrawn
· Kinsei Sangyo and their representatives should be excluded from consideration for any Cleveland waste treatment installations or contracts
· The contract that would have award $1,500,000 to a contractor when they get a permit should be immediately terminated, and they should be paid nothing
· The possibility of suing and prosecuting Kinsei Sangyo and their US representatives and contractors who spearheaded this misrepresentation of the proposed technology should be considered
· The $1,500,000 saved should be used to prepare an environmental impact statement focusing all reasonable municipal waste recycling and treatment alternatives (at both the city and at a county level). The purpose of an EIS is to provide decision-makers and the general public with information that they need to make informed decisions. The alternatives in the EIS should be summarized with their estimated costs, pros and cons, uncertainties, etc. The alternatives should be worded in the form of draft resolutions that the Cleveland City Council and Cuyahoga County government could accept, reject, or amend to further their shared objective of improving their recycling, waste treatment, and disposal programs.
Naturally, the prime contractor hired to do this work must understand the associated technologies and their limitations, and have no financial interest in which alternative is selected.
Being mislead in this way could be embarrassing to Mayor Jackson, CPP and CDAQ. However, if they promptly recognize the problem and implement the above recommendations, they can avoid adverse consequences and accomplish what is needed.
3/2/2012 10:05 PM