COMMENTS ON DRAFT PERMIT TO INSTALLRIDGE ROAD GASIFIERS & INCINERATORS (P0107767)byClaude Lawrence Cornett, Jr.Cornett Environmental Consulting lcornett@en.com
1/9/2012 2:45 PM
AIR POLLUTION SOURCES
Before a draft permit to install should be issued, the detailed specifications for the specific equipmentand processes used for the removal and transport of solids from the gasification furnace, managing process upsets, preventing fugitive emissions, the treatment and disposal of wastewater, maintenance,monitoring, and control need to be proposed and evaluated.
Process Upsets and Fugitive Emissions:
During pyrolysis, if pressures within the system exceed the capability of the system to confine andappropriately control emissions, the resulting emissions and human health impacts can greatly exceedthose from the stacks.Available data on Kinsei Sangyo Gasifier technology shows that it uses a gravity fed verticalconfiguration.
(2)
A common problem with such configurations is the sudden release of much of thecontents of such chambers due to the collapse of bridged material above void spaces. In blast furnaces,this process causes sudden releases of air pollution through safety valves, as those who watchedCleveland’s blast furnaces in the 1970s remember. The oils, waxes, tar droplets, melting material etc.from the pyrolysis process might cause the municipal waste to similarly adhere, bridge, collapse, etc.in the proposed system. Such releases could have adverse effects on public health, safety, and theenvironment.Similar uncontrolled emissions could also happen if a horizontal gasification process, such as rotarycalciners or kilns, is selected. A common problem within rotary thermal treatment processes is theformation of balls and rings of adhering materials whose subsequent behavior causes sudden releasesof gases. The phenomenon is called "puffing.”These types of problems, as well as other process upsets, commonly accounted for most of theobserved adverse air pollution impacts of emerging energy technologies.
(3)
The failure of municipal waste gasification/incineration systems is common.
(16)
At last report, no full-scale municipal waste gasifier/incinerator has been granted a permit to operate in the United States.
(6)
The release of combustible gases from treatment chambers can cause explosions, as illustrated by theexplosion at a municipal waste gasification incinerator in Karlserue, Germany.
(4)
No test data is available on the proposed process using Cleveland’s municipal waste, and the specific process to be used has not been adequately defined. Appropriate tests are needed to establish thesafety, stability, and effectiveness of the specific process to be used.In addition, any associated emissions need to be included in the projected emission inventory for the proposed installation (not just emissions through the smokestack) and in modeling of emissions andtheir impacts on ambient air quality. These emissions should be considered when deciding at what percentage of capacity the proposed installation can be allowed to operate, etc.1
Solid Waste Handling:
In the 1970s, a multimillion-dollar study by NASA (in collaboration with the Cleveland Division of Air Pollution Control, the Cleveland Clinic, and Blue Cross) revealed high cancer levels in Clevelandcaused air pollution from the former Republic Steel coke ovens. These were largely due touncontrolled emissions during the discharge of coke and from leaks in the ovens. Despite an attempt by Cleveland former Mayor Perk to cover them up, those findings resulted in enough public pressureto shut down the worst of the ovens and seal leaks and install and operate pollution control equipmenton the coke discharge process on the others.The proposed batch pyrolysis gasification process resembles that of a coke oven. However, cokeovens pyrolyze coal, and the proposed process pyrolyzes municipal waste in a process that is muchmore complicated than a conventional coke oven.Municipal waste pyrolysis creates benzene, other aromatic compounds, organochlorines, dioxins,furans, unstable, chemically reactive compounds, other carcinogens, and flammable gases andaerosols.
(1)(5)
This indicates that air pollution emissions from very short duration processes associatedwith the removal of residual ash and solids from the gasifiers, emergency pressure relief, and leaks can pose a major threat to human health and the environment. Under the circumstances, the three-minuteexclusion from the prohibition of visible emissions from ash removal in the proposed permit mightallow frequent and environmentally significant releases during normal daily operations, depending onthe nature of the ash removal and gas-handling processes (which has not been adequately described).Furthermore, the gases that may be released when ash is discharged from the pyrolysis modules couldcontain significant amounts of oxides of nitrogen and other invisible components -- depending on theexact nature of the currently undefined process and how it is operated and maintained. The detailsneed to be proposed, evaluated, and appropriate monitoring, modeling, and reporting required beforeissuing a draft permit to install.
Odor
The oils, tars, etc produced by the pyrolysis of municipal waste are known to be highly odoriferous.
(5)
The need to control odors from the proposed pyrolysis process and associated systems and activitiesneeds to be evaluated and, if necessary, addressed more specifically than simply citing the nuisanceregulations, as was done on Page 7 item 8 of the draft permit.
Maintenance and Air Emissions from Contaminated Water
Atmosphericemissions and adverse impacts on public health and the environment are possible frommaintenance activities, wastewater ,scrubber water , and other air pollution control byproduct
management processes--unless appropriately prevented and/or controlled.The specifications for the
specific equipment and procedures to be used for these purposes need to be described and evaluated before a permit to install should be granted. This is especially true given the competitive bidding process and the potential impacts of atmospheric emissions on human health and the environment.
Monitoring:
On Page 15, Paragraph c (1), the daily collection and analysis of representative grab samples of syngasis required. Much of the heating value of the fuel that exits the pyrolysis system may be in the form of aerosols and particulate matter containing oils, waxes and tars. These need to be appropriatelysampled and included in the inventory of the heat content of the syngas. At least one specific and2
appropriate method of sampling and analysis needs to be proposed and approved before a permit toinstall should be granted.Given the short durations in which puffing can take place, average opacities should be measured everysecond or two, and an appropriate frequency of recording opacities needs to be specified. This is pertinent to Page 24, section 4 Paragraph a. In addition, appropriate regulation, continuousmonitoring, and reporting of fugitive emission opacities should be required.The proposed monitoring and reporting of process conditions is inadequate to detect if pollutioncontrol equipment is maintained and operated properly. For example, for the baghouse, only pressuredrop monitoring is required in the draft permit. See Paragraph 5 on pages 24 and 25 for details. Whilesuch monitoring can detect gross failures of baghouses, it is not sensitive enough to detect if bags needto be replaced etc. to maintain at least the efficiency that the baghouse had during compliance testing.Under the circumstance, the use of continuous, sensitive, properly calibrated, and maintained fabricfilter leak detection systems should be required for all baghouses.In addition, appropriate regulation, continuous monitoring, and reporting of all potentially significantsources of emissions should be required, including fugitive emission opacities and associated gaseousemissions.
Modeling
Given that:
*
The actual proposal is extremely vague , containing no details about key aspects of the proposedtechnology, such as how ash is unloaded from the gasifier and any associated procedures to preventsignificanttoxic gasemissions, how well it works on Cleveland’s municipal waste, etc.
*
Emission estimates are based on unsupported manufacturer ’s specifications and other informationthat can not be verified, for example:
o
The concentrations of lead , mercury and other substances in the proposed pelletizedmunicipalwasteto be gasified and burned have not been measured, and this informationis
necessary to credibly estimate emissions and impacts on ambient air quality
o
T he technology proposed has never been used on pelletized Cleveland Municipal Waste
*
Only the impacts of stack emissions on ambient air quality were modeled.
o
No fugitive atmospheric emissions were included in the emission estimates and in themodeling of ambient air quality impacts.
o
Potentially significant sources of such fugitive emissions include ash unloading(especially from the pyrolysis modules), process upsets, the treatment of pollution control byproducts, etc were not included in the modeling
o
Fugitive emissions could be significant, given the low bid nature of governmentcontracting and the lack of pertinent specifications in the proposal, draft permit, and associatedsubmissions
o
No process upsets were modeled
o
Fugitive emissions and emissions from process upsets will usually occur at groundlevel, often within the turbulent wake of the building, where the amounts of dilution are muchless than those associated with stack emissions
*
Many toxic contaminants that could have adverse impacts on human health and the environmentare currently unregulated by Ohio EPAIt cannot becrediblyconcluded that the facility, as proposed, will actually emit pollutantsat levels that
comply withthe limitsin the applicable new source performance standards or that the modeling
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COMMENTS ON DRAFT PERMIT TO INSTALL
RIDGE ROAD GASIFIERS & INCINERATORS (P0107767)
by
Claude Lawrence Cornett, Jr.
Cornett Environmental Consulting lcornett@en.com
1/9/2012 2:45 PM
RIDGE ROAD GASIFIERS & INCINERATORS (P0107767)
by
Claude Lawrence Cornett, Jr.
Cornett Environmental Consulting lcornett@en.com
1/9/2012 2:45 PM
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