Clean Air

 

Cleveland's Solid Waste-To-Electricity Proposed Incinerator

Newest information marked with **

Cleveland's proposed trash combustor will be located at the city’s Ridge Road Transfer Station. The plant may be designed to accept 2,000 (to 3,000) tons of trash per day from the entire city of Cleveland and other cities, will operate 24/7, might cost $180 million (current projections), will accept waste from other communities, and might supply about 20 Megawatts of power (most recently projected at 15Mw).

**CPP's Ivan Henderson represented the cityof Cleveland at a Waste Conversion Congress East Coast in Philadelphia on June 13. He mingled with leaders in the waste-to-energy industry and gave a presentation called "Case Study: Early Stage Project Implementation in Cleveland" providing an interesting interpretation of project design objectives and the newest CPP "Supplemental Request for Information and Qualification" for a MSW incinerator (responses due July 31); describes how the city will waste its valuable yard waste, food, paper residuals and other non-hazardous and non-recyclable materials to make fuel pellets; neglects to mention the USEPA critique of the CPP Permit to Install air permit or the firing of consultant Peter Tien for unacceptable errors, faulty research and lack of required professional care and skill; minimizes lead, mercury, particulate matter, and other air emissions from the proposed incinerator; says a local company may modify its own air permit to burn the MSW fuel pellets; and, describes a Road Map for Project Development (un-implemented in Cleveland).

**Scroll down to 'media' below to read a recent Plain Dealer article.

ENVIRONMENTAL JUSTICE

US Environmental Protection Agency defines gasification as incineration.

Here are some documents that clarify gasification=incineration: angelbeck6-12email.pdf, 1992PSD, 1993MRRF and 2009AEG.

AIR POLLUTION PERMIT

The Center for Health, Environment and Justice, Cleveland Tenants Organization, Earth Day Coalition, Environmental Health Watch, Northeast Ohio Sierra Club Coal and Energy Committee Ohio Citizen Action,and Council Brian Cummins, Ward 14, ask USEPA to work with Ohio EPA to deny the air pollution permit devised by recently fired consultant Princeton Environmental and Peter Tien. Read the April 8, 2012 letter.

 The city fires Peter Tien, incinerator project consultant, for lack of required skill and care.


This emission comparison chart shows CPPs original application, the Ohio EPA pollution limits in the draft permit, and the new pollution proposal from CPP. Note that in the new proposal (modification)
particulates (soot) remain unchanged, volatile organic chemicals increase, the total air emissions for lead in the county can increase by up to 50%, and the proposed facility will still be the biggest emitter of mercury at up to 144 pounds per year (the next highest local emitter released 16 pounds in the most recent reporting).

CPP says it will lower air pollution from the incinerator. CPP proposes to eliminate one of the four gasifiers, operate three gasifiers are 96% use, and raise the stacks up to 200 feet. However, raising the stack height will not reduce pollutants but only disperses them over a greater area to reduce certain concentrations to lower levels; and, eliminating one of the four proposed incinerator units does nothing to reduce capacity - four units at 72% use or three units at 96% capacity are identical.

 On February 23, 2012, the City threatens to fire Peter Tien, project consultant, for cause, in 10 days.

  USEPA sent a letter to Ohio EPA commenting on the proposed incinerator's air permit and disagreeing with Ohio EPA's conclusions. USEPA took in account serious community concerns regarding pollution impacts and environmental justice concerns.

  Ohio Environmental Council submits comments on the draft air pollution permit and expresses concern for particulate (soot) mercury and lead emissions, transparency and diesel hot spot emissions.

 The city of Shaker Heights submits comments on the draft air permit and objects to the permit based on the health impacts from such a large new source of air pollution.

Cleveland  Mayor Frank Jackson requests an additional 30-day extension (until February 23, 2012) for written comments on the draft air permit. ( Extension request was granted on January 20.)

 Local groups and Councilman Cummins wrote to EPA requesting that the hearing on Monday be limited to a Q&A session. Requestors suggested testimony given at another time (this has been done for other permits) when more information is available. A letter was received on January 6 from Chris Abbruzzese from OEPA denying the community request.

 Click here for Congressman Dennis Kucinich's (D-OH) statement on the proposed waste incinerator.

Environmental Health Watch, Earth Day Coalition, Ohio Citizen Action, Sierra Club, Center for Health Environment and Justice, and Natural Resources Defense Council asked US EPA, Region 5 in Chicago to review the trash incinerator draft permit and designate the permit as being located in an environmental justice community. USEPA has agreed to review the permit. Download the USEPA letter here.

Ohio EPA draft PTI.

NRDC attorney says secrecy in PTI application (redactions) are legally improper.

CPP application for PTI air pollution permit to Ohio EPA.

AIR POLLUTION EMISSIONS

**Air emissions from this facility are a concern. Click here to see how how some Cuyahoga County emissions from 2010 rank when compared to the proposed trash combustor. Mercury emissions. Particulate emissions. Total emissions. Click here to see a comparison between mercury emissions from operating local coal plants and proposed emissions from the trash combustor. Here's a mercury fact sheet.

Here is a chart that compares pollutants in the CPP air pollution permit application and the draft Ohio EPA air permit at 72% usage - comparisons are in tons per year and also in pounds per year.

The projected particulate emissions (PM) from the plant are comparable to local operating major industrial and utility sources (i.e. coal plants - 2009 data). Click to view a PM Slide here. Our region is not in health-based attainment for particulate air pollution. For more information on PM pollution visit http://www.epa.gov/oar/particlepollution/health.html

The proposed gasification type of incinerator will be the biggest source of airborne mercury releases in Cleveland, and joins major top sources of mercury pollution released into our community, Lake Erie and beyond. The attached chart illustrates a comparision between major sources of airborne mercury releases and the proposed Cleveland incinerator. The coal-fired power plants listed on the chart were built 50 or more years ago and have never installed modern scrubbing technology to reduce emissions; but the incinerator would put out high levels of mercury even with scrubbing technology. For more information on mercury pollution visit www.epa.gov/hg/about.htm

**Click here to download the recently posted air pollution modeling maps from CPP-generated data submitted as part of the recent PTI permit to Ohio EPA. Each map shows the location of the four incinerator units, identifies the highest concentration predicted, and identifies the location where the computer model predicts the highest concentrations are likely to occur. The maps show the average additional pollution that nearby neighborhoods will experience every day for five years if the plant runs at maximum capacity, and all things go as planned. The maps show a model of the impact of mercury, dioxin, lead, particulate matter PM 2.5, nitrogen dioxide, sulfur dioxide, and carbon monoxide at a distance of about 1.2 miles away from the 175-foot stacks (even though the map image is of a much larger area - you have to look for the tiny dots - receptor locations - to see the 1.2 mile modeling area).

ALTERNATIVES - RECYLCING, COMPOSTING

Take a look at  to http://www.ilsr.org/ help understand "waste to wealth," a sustainable approach that promotes local jobs, resource recovery parks, recycling, composting, and refurbishing.

**The recycling goal for the new gasification project is 25% (the 2010 national average is 34%). Take a look at the county's county's annual report on what other cities in Cuyahoga County are recycling now (2010) - 68%, 52%, 47%, 32%, etc. Lots of good information on reducing, recycling and re-using, plus composting is available at the Cuyahoga County Solid Waste District.

City of Cleveland recycling information.

Download and post this  sign in your window to promote recycling and composting. Do you know Neil Seldman says, "For every 10,000 tons of garbage that is burned in an incinerator, one job is created. For every 10,000 tons of raw materials recycled and composted 8-10 jobs are created as a result of value added to the materials."

BEST ADDITIONAL LOCAL SOURCES OF INFORMATION

Ohio Citizen Action (information, resourece and general news coverage) http://ohiocitizen.org/?s= cleveland+waste+energy

Environmental Health Watch (information, resourece and general news coverage) http://www.ehw.org/community-environmental-health/air-pollution/ 

Councilman Brian Cummins (Ward 14) blogspot

ADDITIONAL RESOURCES AND INFORMATION

  **Sierra Club's web page has Zero Waste resources and links (including links to videos on gasification) at www.sierraclub.org/committees/zerowaste/garbage/  Be sure to check out the "Garbage is Not Renewable Energy" link, the "Exclude Garbage from Renewable Standards" link and "Incinerators Trash Community Health" link.

**Download “Incinerators Trash Community Health.” Many proponents of pyrolysis, plasma and gasification incineration assert that these technologies are not incinerators…verified data from full-scale commercial facilities that support this claim have not been produced.

Click here to download a Fact sheet with questions that residents should ask. 

Click here to download a letter to Mayor Jackson from environmental organizations including Earth Day Coalition.

On a pollutants-per-megawatt comparison, the proposed MSW incinerator is dirtier than the proposed and permitted, but never built AMPGS "scrubbed" coal plant. The trash burner is now proposing to generate 15Mw of electricity (down from 20Mw).

Cleveland Public Power Feasibility Study

**Cleveland Public Power'sPower Point Presentation at Community Meetings.

**Princeton Environmental Group's Basis of Design. Log in using Facebook or sign up for Scribd.

For more information on gasification:  www.energyjustice.net/incineration.

The Blue Ridge Environmental Defense League "Waste Gasification, Impacts on the Environment and Public Health" 2009

To view Cleveland facility documents: www.energyjustice.net/map/displayfacility-74591.htm

Environmental Hierarchy of Waste Management & Energy Production Methods / Fuels / Technologies  http://www.energyjustice.n et/files/technologies.pdf

Here's what's in Cleveland's waste.  The facility design. Take a look at how the waste will be treated.

Click here to see a map of the schools, food plants and community gardens near the proposed incinerator:  cleveland_waste_gasification_maps.pdf

Here's some information on the projected capital and operating & maintenance costs of new generating power costs. Municipal Solid Waste (MSW) costs are posted near the bottom of the chart and are the highest among all energy categories. http://www.instituteforenergyresearch.org/2010/11/23/eia-releases-new-generating-plant-capital-cost-data/

Click here to view Cleveland Public Power information on their proposed gasification project.

MEDIA

**Cleveland receives two dozen suggestions for trash management, many similar to controversial waste-to-energy plan, Plain Dealer, 11-22-12

**Controversy Dogs Cleveland's Waste-to-Energy Ambitions, Midwest Energy News, 6-27-12

**From Waste to Watts: Cleveland's Controversial Pursuit of Trash Conversion Technology, Plain Dealer, 6-17-12

**Cleveland's New Garbage Plan Smells Like the Same Old Trash, Cledveland Scene, 6-13-12

Trash incinerator project that won't die, Plain Dealer by Randy Cunningham 4-14-12


Good money follows bad - Cleveland City Council authorizes an additional $200,000 to hire a new consultant (in a 15-2 vote with Cummins and Polensek voting no) to review the city's trash plans, including all types of 'thermal conversion' (aka mass incineration, pyrolysis, gasifcation, etc.). Cleveland Public Power will take the lead, write the RFP and review all responses. All 'new' proposals will be due by July 31.

We need transparency and citizen involvement, Plain Dealer by Ann Marie Knotek 3-28-12

 Cleveland is wise to scale back its trash-to-gas plan: editorial, Plain Dealer: 3-9-12

 Cleveland trash-plant consultant tries to save contract, Plain Dealer: 3-9-12

 
Incinerator with fewer stacks would still be a huge polluter, Plain Dealer by Sandy Buchanan: 3-8-12

 Do the research; get the technology right, Plain Dealer by Therese Pohorence: 3-8-12

 Trapped in Cleveland, Plain Dealer by Judith Brown: 3-8-12

 U.S. EPA forces Jackson to scale back trash-to-gas plan, Cleveland Magazine: 2-24-12

Proposed trash-disposal faces tough fight with Cleveland City Council, Plain Dealer by Tom Ott: 2-6-12

Opponents of gasification facility protest at Cleveland City Hall NewsChannel 5: 1-30-12

 Let's get some answers on gasification 1-27-12 –Sun News editorial 

Public comment period on proposed gasification plant extended Sun News, Mark Holan: 1-21-12

Cleveland air official says proposed plant's emission numbers are high, Plain Dealer by Tom Ott: 1-10-12

Click here to see a Plain Dealer article on the January 9 public hearing for the draft air pollution permit.

 Click here to see TV5 coverage of the public hearing on the draft air permit.

 Watch the 1-3-2012 WKYC TV 3 interview with Sandy Buchanan talking about opposition to the trash plant. 

Click here to link to a December 2011 "Scene" article on the proposed incinerator, titled "The Mysterious Mr. Tien."

 Click here to link to a "Plain Dealer" December 8 editorial that doesn't take into account the enviornmental impacts of the proposed incinerator.

"City of Cleveland hopes to spin garbage into profits with new waste-to-energy plant"
by Mark Gillispie, Plain Dealer, Saturday, May 07, 2011
http://blog.cleveland.com/ metro/2011/05/city_of_clev eland_hopes_to_spi.html

"Is waste-to-energy the answer, or does it lure cities away from recycling?"
by Marc Lefkowitz, GreenCityBlueLake, May 3, 2011
http://www.gcbl.org/blog/m
 arc-lefkowitz/waste-energy -answer-or-does-it-lure-ci ties-away-recycling

"Waste to Electricity?" 90.3 FM WCPN's The Sound of Ideas
http://www.ideastream.org/soi/ entry/40198


NRDC's "Toxic Power"
 Residents of Ohio are exposed to toxic air pollution from coal-fired power plants according to an analysis by the Natural Resources Defense Council (NRDC). "Toxic Power" uses publicly-available data to rank states and power plants based on 2010 air pollution levels as reported to the EPA'a Toxic Release Inventory (TRI). The report reveals that Ohio (#2) only follows Kentucky (#1) among the top 20 toxic U.S. states where residents are at a higher risk of numerous health problems just by breathing.

New E-Check Information                                                                                                                                                                                

Ohio EPA introduced a new, decentralized E-check program called ChoicePlus. Below are highlights of the ChoicePlus program:
·         53 new testing locations in addition to the existing 23 locations.
·         16 new self-service kiosks outside the existing testing stations (available 24 x 7 x 365).
·         RapidScreen remote sensing vans will scan your vehicle emissions as you drive by. Notification will be sent to home along with registration renewal application. Yes! E-check removes 74 tons of harmful emissions each day. For more information click here.

New Air Quality Rules
On July 6 USEPA issued a final rule to reduce ozone and particulate air pollution that crosses state borders. More at www.epa.gov/airtransport/basic.html

Clean Air Program

The Clean Air Program provides members of the public with a comprehensive way to protect local air quality. Two aspects of the program are dedicated to air quality: Air Pollution Permit Trainings and EMPACT. These programs train people to become more aware of the sources of air pollution in their community and make the important connection between air pollution and human health. You can also learn how to take action in your community.

Earth Day Coalition is working cooperatively with the United States Environmental Protection Agency to train citizens across the U.S. to enhance meaningful public participation in both permit development and enforcement in the Title V air pollution permitting process.

We train citizens across the U.S. to enhance meaningful public participation in both permit development and enforcement in the Title V air pollution permitting process These trainings cover both pre-construction and operating permits, which pollutants are regulated, and how to analyze a facility's permit. Trainings have included Introductory Title V trainings, Advanced Title V trainings and New Source Review trainings.

Did you know that large industrial facilities must obtain government-approved permits both before they are built and when they begin to operate? These permits protect our health by telling the facility how much it must cut back its polluting emissions, what kinds of air pollution control technology it must use, and what kinds of monitoring and record-keeping it will use to make sure it's doing what it's supposed to. These permits are the "guidebooks" used by the facility, regulators, and the public, to ensure that our Clean Air laws are being followed.

EDC worked with the New York Public Interest Research Group to produce a resource manual for citizen participation entitled, The Proof is in the Permit: How to Make Sure a Facility in Your Community Gets an Effective Title V Air Pollution Permit. This valuable resource is located online at www.epa.gov/airprogm/oar/oaqps/permits/partic/proof.html

The EMPACT program is titled Environmental Monitoring for Public Access and Community Tracking. EMPACT provides access to near real-time environmental data over your Internet connection. Through the EMPACT website, located athttp://empact.nhlink.net you can check today's levels of ground level ozone air pollution for all of Northeast Ohio. Northeast Ohio is also in non-attainment of the Clean Air Act's standards for ozone. Ground level ozone (smog) is a colorless gas formed when heat and sunlight react with pollutants (Nitorgen oxides - NOx in the presence of Volatile Organics - VOCs).

Click here for today's ground level ozone status, more information and fact sheets. Local air pollution monitors update the site every few hours during the months of April through September.


If urban sprawl also concerns you, try the EMPACT Urban Growth Simulator, which allows you to build virtual homes and businesses throughout our region, and see how much forest or farmland might be lost to various types of development.

Through EMPACT, Earth Day Coalition offers free educational materials, including brochures on air pollution and your health, and two teacher's workbooks on incorporating air pollution and urban sprawl lessons, games and resources into the classroom.

The New Fine Particle Pollution Program (FP3)

Currently, Northeast Ohio is not meeting the fine particle pollution health standards (National Ambient Air Quality Standards) of the federal Clean Air Act.

The Northeast Ohio Areawide Coordinating Agency (NOACA) has begun to advise Northeast Ohio residents when fine particle pollution (soot) reaches unhealthy levels. Particulate pollution consists of microscopic particles in the air from car and truck exhaust, industrial emissions, dirt, dust, smoke, road salt, water vapor and other sources. Click here for today's particulate status, to register for a free health advisory email, or to get more information or fact sheets.