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Taylor Air Permit Application Comments Part II 10.27.10

Taylor Air Permit Application Comments Part II 10.27.10

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Published by: Andy Arthur on Feb 06, 2011
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Main Office:
33 Central Ave, 3
Floor, Albany, New York 12210Phone: (518) 462-5527
Fax: (518) 465-8349
 A Clean Environment* Green Purchasing* Pollution Prevention* Healthy People* Green Jobs* ZeroWaste
October 27, 2010John W. PetronellaEnvironmental Analyst New York State Department of Environmental ConservationDivision of Environmental PermitsRegion 321 South Putt Corners Road New Paltz, NY 12561-1620Re: Taylor Biomass Energy Facility Permit ApplicationsDear Mr. Petronella,Thank you for your assistance in accessing the files and answering our questions. We appreciateyour help. We intend to address both applications at once, because many of the issues areinterconnected, apply to both Solid Waste and Air applications and it seems redundant to repeatthe same thing twice.We are also enclosing an earlier letter regarding the Draft EIS which was signed by manyenvironmental groups and sent to the Town of Montgomery. These and all other commentswhich we have provided to DEC or the Town of Montgomery and copied to DEC shouldconstitute the entire record of our comments for the proposed Taylor facility.1.
The NYS Department of Environmental Conservation should deny any permits for thisexperimental facility. Currently there is no commercial facility in the nation that usesgasification for mixed solid waste.
 The track record elsewhere on these newer versions of garbage incinerators points to serious problems. We are enclosing two reports for background information:
 Incinerators in Disguise
 An Industry Blowing Smoke
. Many of the newer versions of incinerators-- gasification, plasma arc and pyrolysis-- have been defeated at the local level because project proponentsmisrepresented the capability of the technology or the costs or lied about the emissions, oftenclaiming zero emissions. All of these technologies use staged incineration. We urge particular attention to the Thermo-select facility, located in Germany. It had difficulty producing energy tothe grid. Many communities had to find other ways to deal with their garbage. It was such afailure that the local community and newspaper dubbed it "Thermo-defect". Finally after a largetoxic release it was permanently shut down. The large German energy company that contracted
for the facility lost almost $500 million and had had enough. It severed its relationship withThermo-select and cancelled plans for a second plant.Given the difficult economic times the state is experiencing, and the extreme cutbacks theagency has experienced, this is just the kind of project that should not be permitted. It is a projectthat will need monthly monitoring, not semi-annual reports that are allowed an additional 60 for submission. DEC must deal with the facts, while ignoring the obfuscations that have been presented by the applicant.
2. DEC is for some bizarre reason having difficulty regulating this facility for what it is -- asolid waste incinerator. We urge DEC to study the definitions found in your ownregulations as well as EPA' definitions for municipal waste combustors and approach thisproject as what it is -- an incinerator for muncipal solid waste.
 EPA's definition under 40CFR Part 60 Subpart EB 60.51b Definitions (underlining is ours)Municipal waste combustor, MWC,
municipal waste combustor unit: (1) Means any setting or equipment that combusts solid, liquid, or gasified municipal solid waste including, but not limited to
 , field-erected incinerators (with or without heat recovery), modular incinerators(starved-air or excess-air), boilers (i.e., steam generating units), furnaces (whether suspension- fired, grate-fired, mass-fired, air curtain incinerators, or fluidized bed-fired), and  pyrolysis/combustion units.
EPA also refers to Incinerators processing 250 tons per day of municipal solid waste as beingsubject to New Source Performance standards.DEC regulations
(1) Solid waste means, except as described in paragraph (4) of this subdivision, any garbage, refuse, sludge from awastewater treatment plant, water supply treatment plant, or air pollution control facility and other discarded materials including solid, liquid, semi-solid, or contained gaseous material, resulting from industrial, commercial,mining and agricultural operations, and from community activities, but does not include solid or dissolved materialsin domestic sewage, or solid or dissolved materials in irrigation return flows or industrial discharges that are point  sources subject to permit under 33 USC 1342, as amended (86 Stat. 880), or source, special nuclear or by-product material as defined by the Atomic Energy Act of 1954, as amended (68 Stat. 923) except as may be provided byexisting agreements between the State of New York and the government of the United States (see section 360-1.3 of this Part).(2) A material is discarded if it is abandoned by being:(i) disposed of;(ii) burned or incinerated, including being burned as a fuel for the purpose of recovering usable energy; or (iii) accumulated, stored or physically, chemically or biologically treated (other than burned or incinerated) instead of or before being disposed of.
(157) Solid waste incinerator means an incinerator combusting solid waste or solid waste in combination with fossil  fuel with or without energy recovery.(158) Solid waste management facility means any facility employed beyond the initial solid waste collection processand managing solid waste, including but not limited to: storage areas or facilities; transfer stations; rail-haul or barge-haul facilities; landfills; disposal facilities; solid waste incinerators; refuse-derived fuel processing facilities; pyrolysis facilities; C&D debris processing facilities; land application facilities; composting facilities; surfaceimpoundments; used oil storage, reprocessing, and rerefining facilities; recyclables handling and recovery facilities; waste tire storage facilities; and regulated medical waste treatment facilities. The term includes all  structures, appurtenances, and improvements on the land used for the management or disposal of solid waste.(159) Solid waste incinerator process train means the solid waste incineration chute to stack equipment. Thisequipment would generally include a feed chute or charging hopper, combustion system, boiler, air pollutioncontrol devices and ash residue system.
§219-1.1 Definitions
(10) Municipal solid waste incineration facility. A facility that is owned, operated, or utilized by, or under contract with, a municipality or political subdivision and which
utilizes hightemperature thermal destruction technologies, including combustion for the recovery of thermal value or for the disposal of municipal solid waste.
 Note: A municipal solid waste incineration facility may also be an infectious waste incineration facility.(11) Private solid waste incineration facility.
 Any facility, other than a municipal solid waste facility, that burns municipal solid waste, or any fuels derived from municipal solid wasteusing thermal destruction technologies, with or without energy recovery.
The Taylor facility is private, and it plans to use staged incineration- first gasifying the waste,then combusting it. There will be two streams following the gasifier-- a gas which will becombusted in a turbine generator and a solid char which will be combusted in a combustionreactor. Taylor likes to refer to his facility as gasification only but the reality is that gasificationis followed by combustion. One of the major problems here is that the gas needs to be cleaned before being used as a product gas, and details about this step are still unknown as Taylor has notsupplied the information. If not adequately "cleaned" the product gas itself will be a key sourceof air contaminants. Overall destruction efficiency of volatile and semi-volatile compounds will be critical for protecting public health.The Massachusetts DEP has recently extended its moratorium on incineration and included thenewer versions in the moratorium. We believe New York should do the same. See the NewYorkers for Zero Waste Platform, which contains a recommendation for a moratorium onincineration, Attachment #1.
3. We remain hopeful that DEC will deny any permits to this flawed project. In the absenceof a denial, we are hopeful that DEC will make major modifications, include stringentconditions, additional monitoring and reporting in the permits, which are needed for anexperimental facility of this kind.

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