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 by waste-to-energy goal 3. Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability 4. Pollution and other public concerns

1. Flaws in the process and project development

A. Internal review and selection of WTE gasification technology was made without third-party expert analysis of waste and energy options. Project initiated without integrated resource plans for Waste Division or CPP. Permit application submitted without prior public process, based on a no-bid, high-risk emerging technology. 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. City s total recycling rate is below 4% with only 26% coverage of city and 5-years of implementation.

B. C.

D.

Project Development Process

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

1. Flaws in the process and project development - continued

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

2. Expert analysis, due diligence, review of 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, project components developed assessed and confirmed as feasible

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

4. Competitive bidding, project partner development, project components re-assessed, refined, confirmed

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

5. Begin project implementation, permit application, project design, financing developed

4. Competitive bidding, project partner development, project components re-assessed, refined, confirmed [ Narrow RFIQ issued with limited responses intended to quasi-bid gasification technology, no new companies responded for gasification technology component.]

6. Construction Management, operating, safety regulations, phasing of project components.

6. Construction Management, operating, safety regulations, 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 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, energyefficient 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 Council s re-approval).

2. Best practices in waste management - continued

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 community s input in developing your plan, so as to
ensure an informed public and to increase public acceptance

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 EPA s current waste management hierarchy and local government integrated solid waste management plans, that include existing and planned waste prevention, waste reduction and 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
http://epa.gov/climatechange/wycd/waste/downloads/overview.pdf REF: SWANA TECHNICAL POLICY T-8, 1/12/2012 http://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 options for waste management

hierarchy places emphasis on reducing, reusing, and recycling the majority of wastes.
[1] Reducing MSW generation most effective

[2] Reusing materials second best method. [3] Source-separated yard waste
composted aerobically to produce soil 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.

[4] Capturing the material value through recycling should be considered next. [5 & 6] Combustion or gasification with energy recovery, or WTE, is the environmentally
preferable route for mixed solid wastes that are neither recyclable nor compostable.

[7] Landfilling MSW is the least preferred option. However, community decisions are based both
on environmental and economic factors.
http://www.epa.gov/osw/nonhaz/municipal/wte/nonhaz.htm http://greentie.naem.org/tag/waste-management-strategies

3. Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability A. Gasification 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 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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Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability - continued

Gasification Facilities in operation worldwide: Seven plants currently 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. Reliability: gasification systems have limited MSW operating history on which to rely they 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 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 estimates that are speculative, theoretical, or market driven. Unless a vendor s cost proposals are backed by substantial guarantees of performance, they cannot be considered reliable.
REF: Meeting the Future: Evaluating the Potential of Waste Processing Technologies to Contribute to the Solid Waste Authority s 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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Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability - continued

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-term commercial 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 Authority s 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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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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Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability - 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 http://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf

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Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability - 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 http://www.gbbinc.com/speaker/GershmanWCCWC2011.pdf

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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 Don t Forget More Recycling Too! By Harvey Gershman, Gershman, Brickner & Bratton, Inc. http://www.gbbinc.com/speaker/wte.pdf

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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:

Actual Project Data:

1. Private sector, biomass combustion facility,

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

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

Select MSW to Energy Projects

1. 16.5 MW, MSW to RDF + Biomass fuel St. Croix, US Virgin Island, Construction Spring 2012 20 MW, MSW Gasification Plant Oregon, Operational Oct. 2012 37.5 MW, Waste Gasification Plant Plainfield, Connecticut, Operational Dec. 2013 22 MW, MSW Plasma Gasification St. Lucie County FL, Operational 4th QTR 2013 10 M Gallons, MSW Gasification Ethanol Edmonton, Alberta, Operational 4th QTR 2012

2012. Initial permit application included burning petroleum coke, that fuel source has been removed from consideration.

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

NOTE: demonstration plant, no costs available from company.

25 tons/day MSW.

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

of wood 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 1980 s promoted by the State of Connecticut.

2.

3.

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

4. (600 tons MSW & 60 tons tires). Note: Originally planned
for 60MW, 3,000 ton/day. No predictions on when it will be operational, pending financing.

5.

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

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 testing and validation, at Enerkem's pilot and commercial demonstration facilities in Quebec.

REF: Public Meeting Presentation 1/19/2012 (Rev. 1/25/2012)

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Proposed thermal gasification technology has too many high risks and costs and could jeopardize CPP viability - continued

City s 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 facility s 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 technology it has not previously been proposed by any other technology suppliers in response to the many RFPs that 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 properly PEG 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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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 Group s (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 Tein s (PEG) estimate with financing:

he s 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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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 or conventional 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 Facilities

[Regarding feedstock]: PEG assumed the heating value of the feedstock (pellets) at 10,000 BTU/lb with a
moisture 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 fluff Without detailed calculations using real data from an existing facility, it is difficult to rely on 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. PEG s 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.

4. Pollution and other public concerns

A. Industry experts warn about opposition by environmentalist and the public regarding first demonstrating high recycling percentages and concern for emissions. Coming under EPA regulations doesn t eliminate the need for public buy-in early on in the project s 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 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.

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%:

State and Regional Pollution rankings & Emission information Mercury and Particulate Matter

Ohio ranks worst in the country for toxic air pollution.

The American Lung Association s 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 nation s 12th highest level of year-round particulate pollution.