City seeks public input on the Cleveland Recycling & Energy Generation Center

Please join the City of Cleveland's Conversation about the CREG Center online and at any of our upcoming community meetnigs, including Thursday, January 19, 2012

6 p.m.

Estabrook Recreation Center

4125 Fulton Road

The CREG Center will increase recycling, generate electricity, reduce costs and create jobs

The Cleveland Recycling and Energy Generation Center (CREG) will allow Cleveland to maximize recycling, reduce dumping at landfills, and generate electricity while reducing city operating costs and creating jobs. It is a sustainable solution to the economic and environmental challenges of waste disposal and the need for alternative energy sources today and in the future. The net effect of the CREG Center will reduce the City’s overall carbon footprint.

Here are some facts about how the CREG Center will work:

·         The City of Cleveland will implement automated trash pick up and curbside recycling citywide. Every household will receive a container for recyclable materials to be placed out for convenient pick up.

·         Recyclables and municipal waste will be taken to a state-of-the-art material recovery facility (MRF) where waste will be sorted to ensure that all recyclable materials are recovered, and that hazardous materials, including products containing mercury, are removed from the waste stream.

·         Recyclables will be sold, creating an additional revenue source for the City. Hazardous materials will be disposed of properly. And the remaining municipal solid waste will be converted into fuel pellets.

·         The fuel pellets will then be gasified to create steam. This steam will do two jobs: generate electricity and then sterilize additional waste prior to pelletization.

·         The facility itself is projected to create up to 150 new jobs.

Understanding the impact.

·         Gasification is not incineration. Rather, high heat and limited oxygen convert batches of solid waste fuel pellets into a synthetic gas and ash. The synthetic gas can be used to generate steam and therefore electricity. Potentially, the ash could be used to create decorative bricks, creating an additional revenue stream.

·         Emissions: What we put into the gasification process determines what comes out as emissions. The CREG Center will use a stringent pre-sort process to remove both recyclables and products containing harmful substances like mercury in an effort to reduce or prevent toxic emissions. In other words, 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.   

·         Truck traffic:  Overall, truck traffic will slightly increase – by about one trip (a truck either coming or going) per hour during daily truck operation times. The increase will be due to the additional trucks needed for citywide curbside recycling pickup. This increase is offset in part by a decrease of 20 tractor-trailer trips per day. Currently tractor-trailers are used primarily to haul waste to the landfill. With the CREG Center, the majority of the tractor-trailer trips will be to recycling mills.

Posted Jan 17, 2012

Community members may be interested in the documents and reports produced by Cleveland Public Power, which would operate the proposed facility. Click through. 

Councilman Cummins and Ms. Miller - thank you so much for joining the conversation. I am working with our team to answer some of the more technical comments and questions in your posts but I wanted to respond and let you know that we are listening.

The CREG Center is a comprehensive solution to several challenges the City is facing: what to do with waste in general, including increasing citywide recycling, reducing operating costs related to waste management, increasing revenue, lowering our overall carbon footprint, and creating alternative energy sources for Cleveland Public Power. Because we are still in the process of reviewing the entire facility, we have the ability to adjust our plans to make sure they best meet all of the City's needs for both the immediate and long term future. In fact, the CREG Center as currently designed will continue to be adaptable, based on the needs of the City going forward.

Councilman, you are correct that the air permit process is an important item as we consider the CREG Center, but it is only one part of the entire project. It is our hope that this conversation allows a larger discussion on the entire project.

Regarding the air permit and levels noted within it: It is important to note that the draft air permit under review by the public and OEPA identifies the maximum levels the facility would be permitted to generate.  Because of concerns over emissions, including toxins like mercury, the City reviewed the pre-sort process and changed our plans during the course of 2011 so that we will be able to remove as much of the harmful waste from the feedstock for the gasifier as possible.

Ms. Miller - I'm very glad that you raised the question of recycling.  The City of Cleveland wants to ensure that every household in Cleveland recycles.  With the CREG Center, we will have a funding source to implement citywide curbside recycling pick up faster than we can currently deliver this service to every home in Cleveland. Each household in Cleveland would receive two bins: one for recyclables and one for other waste. At the proposed material recovery facility, employees will further sort through all trash (in case people do not place all recyclables into their individual recycling containers) to make sure that we pull those items out of the feedstock for the gasifier. The City will then sell those recyclables, increasing that revenue stream for the City.

These are just a couple of the points that are very important for our community to understand regarding the CREG Center.  I look forward to talking with you and others further on these topics and additional points you've raised.

Posted Jan 18, 2012

This evening, please join us for a community meeting on the Cleveland Recycling & Energy Center at Estabrook Recreation Center, 4125 Fulton Road at 6 p.m. We will present the entire vision for the Center and explain where we are in the process. After the presentation, community members will be able to ask questions and offer comments. In order to hear from as many people as possible, each person is asked to limited their time to three minutes. Sign up cards for the Q&A session will be available at Estabrook prior to the start of the meeting. 

Agenda for January 19, 2012 Community Meeting

Welcome and Introductions - Maureen Harper, Chief of Communications

CREG Center Presentation - Jenita McGowan, Chief of Sustainability; Ron Owens, Commissioner of the Division of Waste Collection; and Ivan Henderson, Commissioner of Cleveland Public Power

Q&A Session

Posted Jan 19, 2012

COMMUNITY MEETING NOTICE: Due to an issue with the gym roof at Estabrook Rec Center, tonight's meeting will be held in the conference room of Estabrook.  This room will have very limited seating. We apologize for the inconvenience. If you see this message, please share with your networks.

Thank you.

Posted Jan 19, 2012

Per the post above, "At last report, no full-scale municipal waste gasifier/incinerator has been granted a permit to operate in the United States." 

Does Cleveland really want to be the first in this experiment no one else will even subject their citizens to, without even giving us the information necessary to conduct a full engineering evaluation as suggested by Mr. Cornett above?

Posted Jan 25, 2012

PROBLEMS WITH DRAFT PERMIT FOR RIDGE ROAD GASIFIER/INCINERATOR

Inadequate details for engineering review demonstrates lack of due diligence

• Only generic block diagrams of major components and manufacturer’s unsupported claims considered along with regulatory limits
•  No control of gases from ash unloading from gasification modules specified
• No air pollution controls specified on air pollution control system byproduct treatment (scrubber water treatment, etc)
•  Ductwork, fans, layout and air movers not adequately defined to assure containment
•  Emergency pressure relief valves not considered
• Low bid purchasing leaves many dangerous possibilities

 <!--[endif]-->No tests required prior to installation in Cleveland

•  Stability of Process Unknown on Cleveland Municipal Waste
• High potential for dangerous emissions from process upsets and puffing
• No analysis of sulfur, mercury, lead, etc in Cleveland municipal solid waste

<!--[if !supportLists]-->*        <!--[endif]-->Inadequate monitoring and reporting

•  Method not specified for determining heating value of syngas and associated aerosols, corrected for natural gas usage
• No short durationpacity monitoring and recording to detect puffing, emergency releases
• No testing of emissions except through smokestacks
• Not enough monitoring to determine if pollution control equipment operating properly in between annual emission tests (no baghouse leak detectors, etc.)
• Record keeping only required for 5 years, yet cancer can result decades later

<!--[if !supportLists]-->*        <!--[endif]-->Modeling only covers stack emissions

• Fugitive emissions occur at ground level or within turbulent wake of building
• Air pollution, noise and congestion from truck traffic not covered

<!--[if !supportLists]-->*        <!--[endif]-->Regulatory Deficiencies

• No short duration opacity limits to address process upsets, puffing, etc
• Only regulates 12 substances, many carcinogens etc. not regulated
•  Higher emissions allowed than in permit application and federal regulations
• Need to specify oxygen and temperatures applicable to stack concentration limits
• Permit does not require submission and approval of environmentally significant specifications Permit does not require tests to establish applicability and stability of gasifier on Cleveland waste
• Does not regulate potential severe hazards during shakedown and process upsets, etc
• Requirements in permit fixed, need to include flexibility to add new requirements as information becomes available

<!--[if !supportLists]-->*        <!--[endif]-->Fundamental Flaws in regulatory process

• Cleveland Division of Air Quality has conflict of interest because reports to mayor along with CPP, and OEPA tied in—need to have permit written by USEPA
•  No environmental impact statement required because Clean Air Act excluded from NEPA and no equivalent analysis of reasonable alternatives
•  Clean air act limited air regulation to 12 substances and many more toxic and carcinogenic substance emissions associated with gasification
•  No budget to develop regulations for MSW gasification and incineration
•  OEPA regulation of Air Toxics not protective of public health
• Sham permit:  heat input restrictions limiting operating capacity to 72.24% of combined capacity to avoid MACT requirements wastes resources and inadequately monitored
• No public review and hearings after comment period on draft permit complete, and major modifications to permit application and permit terms and conditions possible

For details see: http://www.cornettenv.org/1-18-2012-ComPermitIncin.htm

Chef Jonathan Sawyer weighs in. 

This article published on January 23, 2012 in Crain's Cleveland titled "Utility sees numerous benefits in trash-to-energy plant". Reflects much of what has been said in this conversation thus far. Check it out. 

All this talk of where our garbage goes and how no one wants it in their own backyard, reminds me of one of my earliest lessons about sustainability... it's a Shel Silverstein poem I used to read as a kid, and have never been able to forget called "Sarah Cynthia Sylvia Stout Would Not Take the Garbage Out"

See for yourself (note: it's a lot more fun to read aloud)

On Friday, we sat down with some representatives from the City of Cleveland to directly ask them about some of the concerns namy of you have been raising in this conversation. Here is the unedited audio from that interview.   

I worked for the US DOE and US EPA on both batch and continuous process gasification and incineration, and for batch and continuous municipal waste incinerator manufacturers. 

Patents for the currently proposed Kinsei Sango process are titled “Method of incinerating waste material by way of dry distillation and gasification” http://www.patents.com/us-5619938.html, “apparatus for incinerating waste material” http://www.patents.com/us-5213051.html,  and “Waste incineration disposal method”  http://www.freepatentsonline.com/6746497.html. 

The eight Kinsei batch dry distillation furnaces in its current proposal would burn municipal waste to ash from the bottom up under smoldering, oxygen starved conditions.  The resulting soot, tars, waxes, oils, other 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. The thermal waste treatment process is classified by US EPA as controlled-air incineration, also known as starved-air incineration or two-stage incineration <http://www.epa.gov/ttnchie1/ap42/ch02/final/c02s03.pdf>.  The emission factors used in the permit reflect that classification. Kinsei Sango correctly calls itself an “Energy Incinerator Plant Company” http://www.kinsei-s.co.jp/index2.htm.  

Clearly, CPPs purpose for referring to the proposed thermal treatment process as gasification and not incineration is deceiving people to think that it something different and safer, which it is not. 

Posted Feb 10, 2012

This is part of an email I sent to Maureen Harper after the last community meeting at the Harvard Recreation Center. At that meeting, I addressed reducing the waste sent to landfills by composting and also asked that the two slices of the waste stream pie chart in their presentation currently labeled "miscellaneous organic" and "other" be more accurately defined. I said that I would expect the answer to that question at the next meeting.

"I saw Jenita's interview in Freshwater Cleveland today and am glad to know that the Westside Market composting pilot is cost neutral. Based on my talks with Professor Rattan Lal at OSU, I am certain that a citywide composting effort can be not only cost neutral, it can be revenue generating as well as healing to our soils, remediatng to our brownfield and it can improve water quality by improving rain absorption and stemming runoff, while also reducing o9ur carbon footprint.

I am thrilled to see that CPP will be the recipient of the energy produced by the biodigetser in Collinwood. I'm sort of surprised that this hasn't been mentioned as part of the portfolio diversification the power company discusses in these presentations.

All along, while I strongly agree that we need, not only as cities, but also as a county and a region, to reduce our land filling practices, I concurrently need to ask how we can do this without adding to our already untenable amount of pollution. How can we do this AND continue to improve air quality AND reduce greenhouse gas emissions? Composting and recycling are the way.

I am impressed with the work of Commissioner Owens in his recycling efforts, and I know that the city's finances can improve through the sale of recyclable materials, as he notes, when the city can sell directly and eliminate the middleman. But even more important as the oft repeated mantra "there is no away", there can be a very significant healing capability achieved by the city in keeping its compostable materials. This same effort can simultaneously reduce our carbon footprint and our costs. The long time investment of our tax dollars has produced the technology at the Ohio Agricultural Research and Development Center (OARDC). Dr. Lal referred me to (and I refer you to) Dr. Harold Keener. Additionally the Bioproducts and Bioenergy Research Laboratory (BBRL) is making strides annually to improve our environment. The work of these scientists has already received our investment and it would be a coup for the Mayor to shift his focus to Wooster from Japan and faraway technology providers. It is the very epitome of "think globally, act locally."

Dr. Keener recently retired from his post at OARDC, but Dr. Lal indicated that he is still very much involved and interested in continuing his work. He can be reached at keener.3@osu.edu. The space needed for composting is not grand, a photo and measurements of the operation can be seen here at the bottom of the page. If Cleveland has one thing in abundance, it is vacant land. I imagine potentially several composting sites in the city's neighborhoods providing a place for organic wastes, food scraps, yard waste to be composted, giving back to our soils, our ability to grow our own food, reducing the expense of land filling as well as the expense of trucking in large amounts of expensive top soils to cover vacant residential and commercial lots, reducing runoff and assisting the NEORSD in achieving compliance with the consent decree.

One last question to add to the one I asked last night to be addressed in the next presentation regarding other and miscellaneous organics; The 2010 report from the city to the County Solid Waste District indicates the city's waste tonnage to be 167,885. How is it then that the numbers this presentation relies on are 230,000 tons of MSW? Did the city's waste increase by 62,155 tons in one year? And as the population continues to thin, do we expect to be adding waste to that stream? Does the larger figure include demolition waste? I'm just curious as to how the figures were calculated.

So again, if the city's waste stream is 62% recyclable, and if we add composting to that the reduction, our land filling would be only 23%. Recycling and composting 77% of the city's waste stream would generate revenue to pay the bonds, and it would not only recycle materials, it would reuse our already invested tax dollars through the use of a local proven innovation - one that is widely sought after, readily visitable, and one that has local experts who can readily consult when needed. It's our tax dollars already at work and producing solutions."

In the CREG powerpoint presentation the costs of the proposed plan are as follows

• Citywide recycling - $29 million
• MSW Receiving Station (MRF) - $21 million
• Recycling Station - $12 million
• Gasification Equipment - $21 million
• Power Plant (20 MW) - $15 million
• Fuel Pellet Equipment (RDF) - $45 million
• Construction - $21 million
• Civil Engineering - $8 million
• Decorative brik Equipment - $8 million
• CREG Total - $180 million

(Does not include the money already pledged to Peter Tien or the $250,000 CPP will ask of City Council to expend for a consultant to wade through the RFI responses.)

Using Lincolln Electric's good example (2.5MW turbine) at a cost of 6 million X 6 - there you have your 15 MWs at a cost of $36 million.

Keep the first three line items and jettison the rest.  The new budget would look like this:

• Citywide recycling - $29 million
• MSW Receiving Station (MRF) - $21 million
• Recycling Station - $12 million
• Wind Turbines - $36 million
• New Total: $98 million

Now granted, I'd like to see the composting operations in here and more aneorobic digesters, too. This is as simplified and opaque a budgeting exercise as CREG proponents are presenting to us, so this is our volley. Ours is a systems approach, too. The big difference is that we do not use that nebulous term "advanced energy". Instead we focus on real renewables. Ours does not spew pollutants into the regions air. We do not seek a silver bullet solution; rather, we focus on disaggregation and decentralization to solve the problem. $98 million is not small, but it's closer to fundable. By the time this thing could possibly be built (I cringe to write those words), Henderson said three years or so, citywide recycling costs would be reduced and perhaps the composting pilot that has shown itself to be cost neutral could be further along. The numbers will change. But I see them changing in a downward direction rather than what has been mentioned in regard to the CREG project that puts actual implementation costs over the $300 million mark.

Then there's this: "We will only poison you a little bit." How do we feel about a government official who stands before us saying that? I don't feel very good about it.

Posted Feb 11, 2012

A lot happened last Thursday, which was the last day the Ohio EPA took comments regarding the draft air permit for the City's proposed MSW WTE facilty.  See the following for coverage of the communications by the U.S. EPA and City of Cleveland's Department of Utilities.

• THURSDAY, FEBRUARY 23, 2012
  
  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. (see full post here)

Ohio Citizen Action takes a look at the new City of Cleveland proposed emission numbers as well as the recent developments in the City of Cleveland's relationship with Peter Tien of Princeton Environmental Group:

• Do the math: ''New'' incinerator proposal would have same amount of dangerous pollutants from soot, more dioxin, and still be the largest polluter of mercury in the county
   
• Cleveland Public Power is disenchanted with Peter Tien
  For a copy of the contract default notice sent by the City of Cleveland to Tien go here. 

And, read a copy of the letter given to Mayor Jackson last night, calling for a withdrawl of the permit application, cancellation of the project, and a refocus of the City’s efforts on developing a strong recycling, composting, and resource recovery program.

• Dear Mayor Jackson: ‘Cancel this ill-conceived project’
  CLEVELAND —  Neighbors from Cleveland, Brooklyn, Lakewood and Cleveland Heights hand-delivered the following letter to Cleveland Mayor Frank Jackson before last night’s City Council meeting:

We've also tried to develop a summary of the issues and concerns we have regarding the proposed facility and have begun to focus on best practices in sustainability and in particular, waste management.  See the following post for detailed analysis:

• 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.

(see full post here)

Posted Feb 28, 2012

 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. 

Posted Mar 02, 2012