PROBLEMS WITH DRAFT PERMIT FOR RIDGE ROAD GASIFIER/INCINERATOR

 

*        Inadequate details for engineering review demonstrates lack of due diligence

o        Only generic block diagrams of major components and manufacturer’s unsupported claims considered along with regulatory limits

o        No control of gases from ash unloading from gasification modules specified

o        No air pollution controls specified on air pollution control system byproduct treatment (scrubber water treatment, etc)

o        Ductwork, fans, layout and air movers not adequately defined to assure containment

o        Emergency pressure relief valves not considered

o        Low bid purchasing leaves many dangerous possibilities

 

*        No tests required prior to installation in Cleveland

o        Stability of Process Unknown on Cleveland Municipal Waste

o        High potential for dangerous emissions from process upsets and puffing

o        No analysis of sulfur, mercury, lead, etc in Cleveland municipal solid waste

 

*        Inadequate monitoring and reporting

o        Method not specified for determining heating value of syngas and associated aerosols, corrected for natural gas usage

o        No short duration opacity monitoring and recording to detect puffing, emergency releases

o        No testing of emissions except through smokestacks

o        Not enough monitoring to determine if pollution control equipment operating properly in between annual emission tests (no baghouse leak detectors, etc.)

o        Record keeping only required for 5 years, yet cancer can result decades later

 

*        Modeling only covers stack emissions

o        Fugitive emissions occur at ground level or within turbulent wake of building

o        Air pollution, noise and congestion from truck traffic not covered

 

*        Regulatory Deficiencies

o        No short duration opacity limits to address process upsets, puffing, etc

o        Only regulates 12 substances, many carcinogens etc. not regulated

o        Higher emissions allowed than in permit application and federal regulations

o        Need to specify oxygen and temperatures applicable to stack concentration limits

o        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

o        Does not regulate potential severe hazards during shakedown and process upsets, etc

o        Requirements in permit fixed, need to include flexibility to add new requirements as information becomes available

 

*        Fundamental Flaws in regulatory process

o        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

o        No environmental impact statement required because Clean Air Act excluded from NEPA and no equivalent analysis of reasonable alternatives

o        Clean air act limited air regulation to 12 substances and many more toxic and carcinogenic substance emissions associated with gasification

o        No budget to develop regulations for MSW gasification and incineration

o        OEPA regulation of Air Toxics not protective of public health

o        Sham permit:  heat input restrictions limiting operating capacity to 72.24% of combined capacity to avoid MACT requirements wastes resources and inadequately monitored

o        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