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8/3/2019 DRAFT Opposition Presentation - CPP MSW WTE
1/20
Major points of research and concerns about CREG Center Project
Major points of research and concerns about CREG Center Project
1. Flaws in the process and project development
2. Best practices in waste management not being
pursued first, project driven bywaste-to-energy goal
3. Proposed thermal gasification technology has
too many high risks and costs and couldjeopardize CPP viability
4. Pollution and other public concerns
8/3/2019 DRAFT Opposition Presentation - CPP MSW WTE
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1. Flaws in the process and project development
1. Flaws in the process and project development
A. Internal review and selection of WTE gasification technologywas made without third-party expert analysis of waste and
energy options. Project initiated without integrated resource
plans for Waste Division or CPP.
B. Permit application submitted without prior public process,based on a no-bid, high-risk emerging technology.
C. Narrow RFIQ released after technology and vendor selected.
Responses are limited and do not include any other gasification
technology providers or address the waste management
component of the project. Credibility issues with consultant
Peter Tien, Princeton Environmental Group.
D. Citys total recycling rate is below 4% with only 26% coverage of
city and 5-years of implementation.
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Project Development Process - 1. Flaws in the process and project development - continued
Project Development Process - 1. Flaws in the process and project development - continued
1. Assessment of scope, goals, systems,
processes, resources, technologies
1. Assessment of scope, goals, systems,
processes, resources, technologies
2. Expert analysis, due diligence, review of best
practices, development of options and actions
2. Expert analysis, due diligence, review of best
practices, development of options and actions
3. Seek community support, project components
developed assessed and confirmed as feasible
3. Seek community support, project components
developed assessed and confirmed as feasible
4. Competitive bidding, project partner development,
project components re-assessed, refined,
confirmed
4. Competitive bidding, project partner development,
project components re-assessed, refined,
confirmed
5. Begin project implementation, permit
application, project design, financing
developed
5. Begin project implementation, permit
application, project design, financing
developed
6. Construction Management, operating, safety
regulations, phasing of project components.
6. Construction Management, operating, safety
regulations, phasing of project components.
1. Assessment of scope, goals, systems, processes, resources,
technologies - INCOMPLETE [focused on alternative WTEtechnologies with no waste management assessment]
1. Assessment of scope, goals, systems, processes, resources,
technologies - INCOMPLETE [focused on alternative WTEtechnologies with no waste management assessment]
4. Competitive bidding, project partner development, projectcomponents re-assessed, refined, confirmed[ Narrow RFIQ issued with limited responses intended toquasi-bid gasification technology, no new companiesresponded for gasification technology component.]
4. Competitive bidding, project partner development, projectcomponents re-assessed, refined, confirmed[ Narrow RFIQ issued with limited responses intended toquasi-bid gasification technology, no new companiesresponded for gasification technology component.]
5. Begin project implementation, [preliminary design] permitapplication, - BUT - project design, financing - NOT developed [cost $1.5 million contract with single-source]
5. Begin project implementation, [preliminary design] permitapplication, - BUT - project design, financing - NOT developed [cost $1.5 million contract with single-source]
Standard based on industry best practices CREG Center
3.
Seek community support, project components developed,
[internal selection of technology and single-source vendorwith review by RNR] assessed and confirmed as feasible
3.
Seek community support, project components developed,
[internal selection of technology and single-source vendorwith review by RNR] assessed and confirmed as feasible
6. Construction Management, operating, safety regulations,phasing of project components.
6. Construction Management, operating, safety regulations,phasing of project components.
2. Expert [Internal] analysis, due diligence, review of [WTE]
best practices, development of options and actions
2. Expert [Internal] analysis, due diligence, review of [WTE]
best practices, development of options and actions
3. seek community support [required EPA comment period]
3. seek community support [required EPA comment period]
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2. Best practices in waste management not being
pursued first, project driven by waste-to-energy goal
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 practices and how to cost
effectively implement reduction, reuse and recycling of waste.
B. No analysis done to seek solutions for monetizing and funding city-wide,
automated curbside recycling. Cost est. $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 solutions. Zero
Waste is the most efficient, highest job producing, sustainable, energy-
efficient climate change solution to waste management.
A. Best practices in the industry point to variable-rate fees and other
incentives for residential and commercial waste streams.
B. Residents perceive current flat $8.50 fee and other polices as punitive
(fee sunsets in 2013 and will require Councils re-approval).
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Solid Waste Association 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 wastemanagement plans, that include existing and planned waste prevention, waste reductionand recycling programs. Permitting of waste to energy facilities should be consistent with
the established long term needs of local government and their integrated solid waste
management plans
US EPA - What Is Integrated Solid Waste Management?
a comprehensive waste prevention, recycling, composting, and disposal program.An effective ISWM system considers how to prevent, recycle, and manage solid waste in
ways that most effectively protect human health and the environment
Do not neglect to ask for the communitys input in developing your plan, so as toensure an informed public and to increase public acceptance
2. Best practices in waste management - continued
2. Best practices in waste management - continued
http://epa.gov/climatechange/wycd/waste/downloads/overview.pdf REF: SWANA TECHNICAL POLICY T-8,
1/12/2012http://swana.org/Portals/TechnicalPolicies/T-8_WTE_PR.pdf
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http://www.epa.gov/osw/nonhaz/municipal/wte/nonhaz.htm
http://greentie.naem.org/tag/waste-management-strategies
2. Best practices in waste management - continued
2. Best practices in waste management - continued
Designed to show the most environmentally
preferable options for waste management
hierarchy places emphasis on reducing,
reusing, and recycling the majority of wastes.
[4] Capturing the material valuethrough recycling should be considered next.
[5 & 6] Combustion or gasification with energy recovery, or WTE, is the environmentallypreferable route for mixed solid wastes that are neither recyclable nor compostable.
[7] Landfilling MSW is the least preferred option. However, community decisions are based bothon environmental and economic factors.
[1] Reducing MSW generationmost effective
[2] Reusing materialssecond best method.
[3] Source-separated yard wastecomposted aerobically to producesoil conditioner
...mixed food and yard wastes, can be anaerobically
digested to generate methane for energy generation and a compost
product that can provide soil amendment value.
Integrated Waste Management Hierarchy (EPA)
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability
A. Gasification technologies for processing MSW are consideredemergingand have not been proved at the scale being
proposed.
B. There are currently no commercial-scale MSW gasification
systems operating in the US and are fewer than five in the world,all using more homogeneous feed stocks.
C. City funds committed so far approach $2 million with another
$250,000 pending for hiring consultant to review responses to
Request For Information & Qualification.
D. Detailed financing options not evaluated; likely use of high-cost,
long-term power contract; cost of facility est. $180-$300 million.
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Reliability:
gasification systems have limited MSW operating history on which to relythey do not have
sufficient experience to draw conclusions for reliability of operation.
Environmental/Air:
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 longexperience 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 vendors cost proposals are backed by substantial guarantees of performance, they
cannot be considered reliable.
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
REF: Meeting the Future: Evaluating the Potential of Waste Processing Technologies to Contribute to the Solid Waste Authoritys System
Solid Waste Authority of Palm Beach County, Florida, 2009. By Gershman, Brickner & Bratton, Inc.
http://www.swa.org/pdf/SWAPBC_White_Paper_9-2-09.pdf
Gasification Facilities in operation worldwide:
Seven plantscurrently operating in Japan, with at least two of them firing MSW[185 tons/day] There are 20 smaller facilities in Europe and Asia. Most of them are
relatively small (>10 tons/day), with none designed for more than 70 tons per day
throughput.
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Conclusions:
3. [in assessing the use of emerging technologies]...[including]
gasification without on-site energy production. If Palm Beach County
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-termcommercial operations under performance-based full-service
contracting arrangements.
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
REF: Meeting the Future: Evaluating the Potential of Waste Processing Technologies to Contribute to the Solid Waste Authoritys System
Solid Waste Authority of Palm Beach County, Florida, 2009. By Gershman, Brickner & Bratton, Inc.
http://www.swa.org/pdf/SWAPBC_White_Paper_9-2-09.pdf
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
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 http://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
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 http://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
Economic Factors
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
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 http://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf
O
pinion: Trends for the Future
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
Reaching Greater Diversion Economically
SWANA North Carolina Chapter Conference 2008 August 27, 2008 - Alternative Technologies to Landfills or:
The Resurgence of Waste-To-Energy (WTE) and Conversion Technologies (CT)and Dont Forget More Recycling Too!
By Harvey Gershman, Gershman, Brickner & Bratton, Inc. http://www.gbbinc.com/speaker/wte.pdf
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
CPP characterization of maturity of
thermal gasification MSW projects: Private sector, biomass combustion facility,200 tons/day of MSW and bio-fuels, $210 millionproject, NOTE: Land lease still in process, unlikely to be built in2012. Initial permit application included burning petroleum
coke, that fuel source has been removed from consideration.
1-2 MW, Private sector, WTE plasma arc gasification,
25 tons/day MSW. NOTE: demonstration plant, no costsavailable from company.
Private sector, biomass gasification project, 250,000 tons
ofwood waste per year, 690 tons/day,$225 million cost, initially estimated at $160 million.NOTE: Region has history of utilizing mass burn facilities, three
incinerator projects built in the 1980s promoted by the State of
Connecticut.
Private sector, thermal plasma project, 668 tons/day
(600 tons MSW & 60 tons tires). Note: Originally plannedfor 60MW, 3,000 ton/day. No predictions on when it will be
operational, pending financing.
Private Sector, 275 tons/day, with 25-year bio-fuelpurchase from City of Edmonton, pre-sorted MSW,
100,000 tons per year. NOTE: Result of several years ofresearch and over 6,000 hours of testing and validation, at
Enerkem's pilot and commercial demonstration facilities in
Quebec.
1. 16.5 MW, MSW to RDF + Biomass fuel
St. Croix, US Virgin Island, Construction Spring 2012
1.
2.
3.
4.
5.
Actual Project Data:
2. 20 MW, MSW Gasification Plant
Oregon,OperationalOct. 2012
3. 37.5 MW, Waste Gasification Plant
Plainfield, Connecticut,Operational Dec. 2013
4. 22 MW, MS
W Plasma GasificationSt. Lucie County FL, Operational 4th QTR 2013
5. 10 M Gallons, MSW Gasification Ethanol
Edmonton, Alberta, Operational 4th QTR 2012
Select MSW to Energy Projects
REF: Public Meeting Presentation 1/19/2012 (Rev. 1/25/2012)
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
Citys consultant reported in 2009 concern over proposed
scale & feedstock as compared to known facilities:
4.3.2 Gasification Technology Overview; 4.3.3 Reference Gasification Facility - Excerpt
In the Cleveland WTE Project Review (page 15), PEG states that Kinsei has more than 250 systems in operation,
processing everything from MSW to chemicals, oil, hospital waste, plastic, rubber, tires and other industrial
hazardous and non-hazardous waste. Most of these systems are quite small in size (3-30 tons/day). In response
to the question regarding the throughput capacity of the existing gasifiers, PEG mentioned that most of the
facilities in Japan have gasifiers with a capacity of 40-100 tons/day, considerably less than the proposed
facilitys 300 to 600 tons/day.
6.1 Technical Issue; 6.1.2 Gasification - Excerpt
The following key issues are noted:
1. The Kinsei Gasification proposed by PEG is not a very well known gasification technologyit has
not previously been proposed by any other technology suppliers in response to the many RFPsthat have been issued by other U.S. cities or counties.
2. Most of the Kinsei gasification units are smaller in size. The design and operation of a gasification
unit for a heterogeneous material like MSW will be challenging, and, in some cases, the different
subsystems will be difficult to size properlyPEG has proposed multiple units to accommodate the
MSW throughput for this project.
REF: Cleveland MSWE Feasibility Study Technical Analysis - RNR Consulting, 2009
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
Concerns regarding capital Outlay Projections that vary greatly:
2009 RNR Consulting Study using Princenton
Environmental Groups (PEG) Estimates based on
2,000 tons/day throughput
2012 Estimates based on 560 tons/day
throughput, 1/19/2012 presentation
December 2011 news article
citing Peter Teins (PEG)
estimate with financing:
hes negotiated a $300 million financing package
if the city chooses a Kinsei plant.
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, http://www.clevescene.com/cleveland/the-mysterious-mister-tien/Content?oid=2772517
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3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
3. Proposed thermal gasification technology has too many
high risks and costs and could jeopardize CPP viability - continued
Concerns Regarding Capital Outlay Projections & Feedstock Throughput Rates 2009 RNR Study:
Conversion technology
suppliers with many years of
experience in design and
operation of MSWE facilities
estimate the cost for an
equivalent 1,000 to 1,200
ton/day MSWE facility utilizing
thermal conversion orconventional mass burn
technologies to be much higher
than the cost provided by PEGREF: RNR Study, 2009, 6.3.2 General Issues, Table 7. Capital and O&M Costs for MSWE Facilities
[Regarding feedstock]: PEG assumed the heating value of the feedstock (pellets) at 10,000 BTU/lb with amoisture content of less than 10%. These fuel pellets constitute only part of the gasification feedstock. In its latest
submittal, PEG mentioned that major haulers could supply additional high BTU industrial and commercial waste such
as scrap tires and auto fluffWithout detailed calculations using real data from an existing facility, it is difficult to relyon these numbers. Thermal conversion, such as using gasification technology to process MSW, is a new and innovative
technology that is only in commercial operation overseas. PEGs proposed facility is in the concept stage.
[Note: Research thus far shows no evidence of an operational thermal gasification waste-to-energy facility of
comparable scale that is using solely MSW. Any comparable size facility in operation or being planned appear to use
a more homogeneous (i.e., wood or tire bio-mass etc) or an added percentage of homogeneous feedstock with
higher BTU/lb ratings that are used to increase total feedstock energy capacity.
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A. Industry experts warn about opposition by environmentalist and the public
regarding first demonstrating high recycling percentages and concern foremissions. Coming under EPA regulations 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 particulate PM(F+C) per year.
B. Though presented as a clean source of energy, gasification produces the
same pollutants as standard incinerators. The facility would be the largest
emitter of mercury, would increase lead air emissions up to 63% and would
be one of the biggest regional soot emitters. All incineration, including
gasification, wastes the energy and resources in municipal solid waste.
C. Environmental Justice concerns include those who live closest will beimpacted 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.
4. Pollution and other public concerns4. Pollution and other public concerns
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Emission information developed from CPP public information and permitapplication
showing the application amounts at 92% use and the Ohio EPAs limits of use at 72%:
Emission information developed from CPP public information and permitapplication
showing the application amounts at 92% use and the Ohio EPAs limits of use at 72%:
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StateandRegionalPollutionrankings &
Emissioninformation MercuryandParticulate Matter
StateandRegionalPollutionrankings &
Emissioninformation MercuryandParticulate Matter
Ohio ranks worst in the country for toxic air pollution.
The American Lung Associations State of the Air 2011 report gives
Cuyahoga County a failing grade for ozone and
particulate pollution levels.
The eight-county Cleveland metropolitan area is
ranked as having the nations 12th highest level of
year-round particulate pollution.
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