DRAFT Opposition Presentation - CPP MSW WTE

8/3/2019 DRAFT Opposition Presentation - CPP MSW WTE

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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


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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.


3/20

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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pursued first, project driven by waste-to-energy goal


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


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



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


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.


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.


9/20

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.





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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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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Economic Factors


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O

pinion: Trends for the Future


13/20





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


14/20





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)


15/20





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


16/20





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


17/20





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.

DRAFT Opposition Presentation - CPP MSW WTE

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