Major

points of research and concerns about CREG Center Project

1. Non-standard faulty process and project phasing and development 2. Best pracCces in waste management not being pursued rst, project driven by waste-to-energy goal 3. Proposed thermal gasicaCon technology and scale is considered emerging, with too many risks and costs that could jeopardize CPPs viability 4. PolluCon, Environmental JusCce issues and need for stronger public educaCon and involvement

1. Process and project development

A. The internal review and selec3on of WTE gasica3on technology was made without third-party expert analysis of waste and energy op3ons. Project ini3ated without integrated resource plans for Division of Waste or CPP. The issue above was further exasperated by an air permit applica3on submission without prior public review, based on a no-bid, high-risk emerging technology being considered at a scale and congura3on not yet proven commercially. Based upon a awed WTE evalua3on process, a narrow RFIQ was released aMer the technology and vendor were already selected. Responses are limited due to a narrow scope and do not address the waste management component of the project. Given the current state of the Citys limited recycling program, in which the Citys total recycling rate is below 4% with only 26% coverage of the city and 5-years of implementa3on with no compos3ng program, the City should rst focus on fully funding recycling city-wide and carry-out and implement integrates resource plans for both the Division of Waste and CPP.
2

B.

C.

D.

Project Development Process

Standard based on industry best pracCces
1. Assessment of scope, goals, systems, processes, resources, technologies

CREG Center
1. Assessment of scope, goals, systems, processes, resources, technologies - INCOMPLETE [focused on alterna3ve WTE technologies with no waste management assessment]

2. Expert analysis, due diligence, review of best prac3ces, development of op3ons and ac3ons

2. Expert [Internal] analysis, due diligence, review of [WTE] best prac3ces, development of op3ons and ac3ons

3. Seek community support, project components developed assessed and conrmed as feasible

3. Seek community support, project components developed, [internal selec3on of technology and single-source vendor with review by RNR] assessed and conrmed as feasible

4. Compe33ve bidding, project partner development, project components re-assessed, rened, conrmed

5. Begin project implementa3on, [preliminary design] permit applica3on, - BUT - project design, nancing - NOT developed [cost $1.5 million contract with single-source] 3. seek community support [required EPA comment period]

5. Begin project implementa3on, permit applica3on, project design, nancing developed

4. Compe33ve bidding, project partner development, project components re-assessed, rened, conrmed [ Narrow RFIQ issued with limited responses intended to quasi-bid gasica3on technology, no new companies responded for gasica3on technology component.]

6. Construc3on Management, opera3ng, safety regula3ons, phasing of project components.

6. Construc3on Management, opera3ng, safety regula3ons, phasing of project components.

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 prac3ces and how to cost eec3vely implement reduc3on, reuse and recycling of waste. B. Insucient analysis done to seek solu3ons for mone3zing and funding city-wide, automated curbside recycling. Cost es3mated at $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 solu3ons. Zero Waste is the most ecient, highest job producing, sustainable, energy-ecient climate change solu3on to waste management. D. Best prac3ces in the industry point to variable-rate fees and other incen3ves for residen3al and commercial waste streams. E. Residents perceive current at $8.50 fee and other polices as puni3ve NOTE: fee sunsets in 2013 and will require Councils re-approval.
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2. Best practices in waste management - continued

US EPA - What Is Integrated Solid Waste Management?
a comprehensive waste prevenCon, recycling, composCng, and disposal program. An eec3ve ISWM system considers how to prevent, recycle, and manage solid waste in ways that most eec3vely protect human health and the environment Do not neglect to ask for the communitys input in developing your plan, so as to ensure an informed public and to increase public acceptance

Solid Waste AssociaCon 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 waste management plans, that include exisCng and planned waste prevenCon, waste reducCon and recycling programs. Permijng of waste to energy facili3es should be consistent with the established long term needs of local government and their integrated solid waste management plans
hkp://epa.gov/climatechange/wycd/waste/downloads/overview.pdf REF: SWANA TECHNICAL POLICY T-8, 1/12/2012 hkp://swana.org/Portals/TechnicalPolicies/T-8_WTE_PR.pdf

2. Best practices in waste management - continued

Integrated Waste Management Hierarchy (EPA) Designed to show the most environmentally preferable op3ons for waste management

hierarchy places emphasis on reducing, reusing, and recycling the majority of wastes.
[1] Reducing MSW genera3onmost eec3ve

[2] Reusing materialssecond best method. [3] Source-separated yard waste

composted aerobically to producesoil condi3oner ...mixed food and yard wastes, can be anaerobically digested to generate methane for energy genera3on and a compost product that can provide soil amendment value.

[4] Capturing the material valuethrough recycling should be considered next. [5 & 6] CombusCon or gasicaCon with energy recovery, or WTE, is the environmentally
preferable route for mixed solid wastes that are neither recyclable nor compostable. on environmental and economic factors.

[7] Landlling MSW is the least preferred op3on. However, community decisions are based both
hkp://www.epa.gov/osw/nonhaz/municipal/wte/nonhaz.htm hkp://green3e.naem.org/tag/waste-management-strategies

3. Proposed gasification technology and scale of project has too many risks and costs and could jeopardize CPPs viability

A. Gasica3on technologies for processing MSW are considered emerging and have not been proved at the scale being proposed. B. There are currently no commercial-scale, MSW gasica3on systems opera3ng in the US. There are fewer than 20 in the world, all appear to be using more homogeneous feed stocks and none are designed for more than 70 to 100 tons per day (TPD) throughput. Most are rela3vely small, i.e., >10 TPD. C. City funds commiked so far approach $2 million with another $250,000 pending for hiring consultant to review responses to Request For Informa3on & Qualica3on focused on gasica3on. D. Detailed nancing op3ons have not been evaluated; likely use of high-cost, long-term power contract for technology that cannot be considered reliable; cost of facility is est. at $180-$300 million.
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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

GasicaCon FaciliCes in operaCon worldwide: Seven plantscurrently opera3ng in Japan, with at least two of them ring MSW [185 tons/day] There are 20 smaller facili3es in Europe and Asia. Most of them are rela3vely small (>10 tons/day), with none designed for more than 70 tons per day throughput. Reliability: gasicaCon systems have limited MSW operaCng history on which to relythey do not have sucient experience to draw conclusions for reliability of operaCon. 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 es3mates for capital and opera3ng costs, based on long experience in the U.S., are the proven mass-burn/waterwall, mass-burn/modular and RDF/dedicated boiler technologies. All of the others have cost es3mates that are specula3ve, theore3cal, or market driven. Unless a vendors cost proposals are backed by substanCal guarantees of performance, they cannot be considered reliable.
REF: Mee3ng the Future: Evalua3ng the Poten3al of Waste Processing Technologies to Contribute to the Solid Waste Authoritys System Solid Waste Authority of Palm Beach County, Florida, 2009. By Gershman, Brickner & Brakon, Inc. hkp://www.swa.org/pdf/SWAPBC_White_Paper_9-2-09.pdf

3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Conclusions:
3. [in assessing the use of emerging technologies]...[including] gasica3on without on-site energy produc3on. If Palm Beach County pursues the use of these technologies, it must be prepared to manage the considerable risks involved, including commercializaCon risks, scale-up risks, performance risks, construcCon and operaCng cost risks and environmental compliance risks. 4. Accessing these technologies is best done through a compeCCve public procurement and negoCaCon process that requests proposals from contractors that are able to provide a facility and services with appropriate nancial guarantees to deliver the permijng, design, construc3on, start-up and acceptance tes3ng, and long-term commercial operaCons under performance-based full-service contracCng arrangements.
REF: Mee3ng the Future: Evalua3ng the Poten3al of Waste Processing Technologies to Contribute to the Solid Waste Authoritys System Solid Waste Authority of Palm Beach County, Florida, 2009. By Gershman, Brickner & Brakon, Inc. hkp://www.swa.org/pdf/SWAPBC_White_Paper_9-2-09.pdf

3. Proposed thermal gasicaCon and risks of adopCng emerging technology - 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 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf

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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Economic Factors

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 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf

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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Opinion: Trends for the Future

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 hkp://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf

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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Reaching Greater Diversion Economically

SWANA North Carolina Chapter Conference 2008 August 27, 2008 - Alterna3ve Technologies to Landlls or: The Resurgence of Waste-To-Energy (WTE) and Conversion Technologies (CT)and Dont Forget More Recycling Too! By Harvey Gershman, Gershman, Brickner & Brakon, Inc. hkp://www.gbbinc.com/speaker/wte.pdf

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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

CPP characterizaCon of maturity of thermal gasicaCon MSW projects:
Select MSW to Energy Projects
1. 2. 3. 16.5 MW, MSW to RDF + Biomass fuel St. Croix, US Virgin Island, ConstrucCon Spring 2012 20 MW, MSW GasicaCon Plant Oregon, OperaConal Oct. 2012 37.5 MW, Waste GasicaCon Plant Plaineld, ConnecCcut, OperaConal Dec. 2013 22 MW, MSW Plasma GasicaCon St. Lucie County FL, OperaConal 4th QTR 2013 10 M Gallons, MSW GasicaCon Ethanol Edmonton, Alberta, OperaConal 4th QTR 2012

Actual Project Data:

1. Private sector, biomass combusCon facility,

200 tons/day of MSW and bio-fuels, $210 million

project, NOTE: Land lease s3ll in process, unlikely to be built in

2012. Ini3al permit applica3on included burning petroleum coke, that fuel source has been removed from considera3on.

2. 1-2 MW, Private sector, WTE plasma arc gasicaCon,

25 tons/day MSW. NOTE: demonstra3on plant, no costs

available from company.

3. Private sector, biomass gasicaCon project, 250,000 tons

of wood waste per year, 690 tons/day, $225 million cost, iniCally esCmated at $160 million.
NOTE: Region has history of u3lizing mass burn facili3es, three incinerator projects built in the 1980s promoted by the State of Connec3cut.

4. 5.

4. Private sector, thermal plasma project, 668 tons/day

for 60MW, 3,000 ton/day. No predic3ons on when it will be opera3onal, pending nancing.

(600 tons MSW & 60 tons Cres). Note: Originally planned

5. Private Sector, 275 tons/day, with 25-year bio-fuel

REF: Public Mee3ng Presenta3on 1/19/2012 (Rev. 1/25/2012)

purchase from City of Edmonton, pre-sorted MSW, 100,000 tons per year. NOTE: Result of several years of

research and over 6,000 hours of tes3ng and valida3on, at Enerkem's pilot and commercial demonstra3on facili3es in Quebec. 14

3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Citys consultant - RNR reported in 2009 concern over proposed scale & feedstock as compared to known faciliCes:
4.3.2 GasicaCon Technology Overview; 4.3.3 Reference GasicaCon Facility - Excerpt In the Cleveland WTE Project Review (page 15), PEG states that Kinsei has more than 250 systems in opera3on, processing everything from MSW to chemicals, oil, hospital waste, plas3c, rubber, 3res 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 quesCon regarding the throughput capacity of the exisCng gasiers, PEG menConed that most of the faciliCes in Japan have gasiers 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 GasicaCon - Excerpt The following key issues are noted: 1. The Kinsei GasicaCon proposed by PEG is not a very well known gasicaCon technologyit has not previously been proposed by any other technology suppliers in response to the many RFPs that have been issued by other U.S. ciCes or counCes. 2. Most of the Kinsei gasica3on units are smaller in size. The design and operaCon of a gasicaCon unit for a heterogeneous material like MSW will be challenging, and, in some cases, the dierent subsystems will be dicult to size properlyPEG has proposed mul3ple units to accommodate the MSW throughput for this project.
REF: Cleveland MSWE Feasibility Study Technical Analysis - RNR Consul3ng, 2009 15

3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Concerns regarding capital Outlay ProjecCons that vary greatly:
2009 RNR Consul3ng Study using Princenton Environmental Groups (PEG) EsCmates based on 2,000 tons/day throughput 2012 EsCmates based on 560 tons/day throughput, 1/19/2012 presenta3on

December 2011 news arCcle ciCng Peter Teins (PEG) esCmate with nancing:

hes negoCated a $300 million nancing package if the city chooses a Kinsei plant.
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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, hkp://www.clevescene.com/cleveland/the-mysterious-mister-3en/Content?oid=2772517

3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Concerns Regarding Capital Outlay ProjecCons & Feedstock Throughput Rates 2009 RNR Study:
Conversion technology suppliers with many years of experience in design and opera3on of MSWE facili3es es3mate the cost for an equivalent 1,000 to 1,200 ton/day MSWE facility u3lizing thermal conversion or conven3onal mass burn technologies to be much higher than the cost provided by PEG

REF: RNR Study, 2009, 6.3.2 General Issues, Table 7. Capital and O&M Costs for MSWE Facili3es

[Regarding feedstock]: PEG assumed the hea3ng value of the feedstock (pellets) at 10,000 BTU/lb with a

moisture content of less than 10%. These fuel pellets consCtute only part of the gasicaCon feedstock. In its latest submikal, PEG men3oned that major haulers could supply addiConal high BTU industrial and commercial waste such as scrap Cres and auto uWithout detailed calcula3ons using real data from an exis3ng facility, it is dicult to rely on these numbers. Thermal conversion, such as using gasica3on technology to process MSW, is a new and innova3ve technology that is only in commercial opera3on overseas. PEGs proposed facility is in the concept stage. [Note: Research thus far shows no evidence of an operaConal thermal gasicaCon waste-to-energy facility of comparable scale that is using solely MSW. Any comparable size facility in operaCon or being planned appear to use a more homogeneous (i.e., wood or Cre bio-mass etc) or an added percentage of homogeneous feedstock with higher BTU/lb raCngs that are used to increase total feedstock energy capacity.
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3. Proposed thermal gasicaCon and risks of adopCng emerging technology - continued

Review of Citys Request for InformaCon & QualicaCons Kinsei Sangyos response provides informa3on on
approximately 100 opera3ng and commercial facili3es with capaci3es of between 1 - 60 tons per day. They note a total of 260 systems in opera3on. Their reference technology is a 35 ton per day, MSW to steam facility in Hoengseong-Gun, Korea that opened in November, 2005. Addi3onal reference facili3es include three 40, 24, and 12 tons per day facili3es, all using industrial solid waste to ash being in opera3ons since 2003, 2006 and 2011 respec3vely.

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Summary of Responses to Citys Request for InformaCon & QualicaCons

Thermal Conversion Technology Providers Waste Handling Equipment Suppliers Financial Service Companies X X X X X X X X X X X X X X X X X X X X X X 5 3 X 10 X 4 3 X

Company

Project Developers

Consultants

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17.

Alternative Resources, Inc. ARCADIS-Malcolm Pirnie Cleveland Thermal Compact Cooling Solutions DLZ Dongara Pellet Plant LP & Remasco Envision Waste Services Gershman, Brickner & Bratton, Inc. (GBB) HDR Engineering, Inc. (HDR) Indiana Recycling and Renewable Fuels Kinsei Sangyo Middough Municipal and Financial Services Group Ralph Tyler Companies SAIC Energy, Environment & Infrastructure, LLC (SAIC) Wells Fargo Securities WSI Management Inc.

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4. PolluCon, Environmental JusCce issues and need for stronger public educaCon and involvement
A. Industry experts warn about opposiCon by environmentalist and the public regarding rst demonstraCng high recycling percentages and concern for emissions. Coming under EPA regula3ons 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 par3culate PM(F+C) per year. B. Though presented as a clean source of energy, gasica3on produces the same pollutants as standard incinerators. The facility would be the largest emiter of mercury, would increase lead air emissions up to 63% and would be one of the biggest regional soot emiters. All incinera3on, including gasica3on, wastes the energy and resources in municipal solid waste. C. Environmental Jus3ce concerns include those who live closest will be impacted 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.
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Emission information developed from CPP public information and permit application showing the application amounts at 92% use and the Ohio EPAs limits of use at 72%:

Air Modeling:

Project team has not yet responded to requests for air modeling data that could be understood by the public. This data was requested in December 2011. It is likely this informa3on will not be made available prior to EPA Public Comment period being closed. This informaCon would provide details of emission levels and esCmaCons of direcCons and distances traveled.

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State and Regional PolluCon rankings & Emission informaCon Mercury and ParCculate Mater
Ohio ranks worst in the country for toxic air polluCon.
The American Lung Associa3ons State of the Air 2011 report gives

Cuyahoga County a failing grade for ozone and parCculate polluCon levels.
The eight-county Cleveland metropolitan area is

ranked as having the naCons 12th highest level of year-round parCculate polluCon.

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