PEG Basis of Design Report 08-31-2011

Cleveland WTE Project
BASIS of Design
Report Date: 08-31-2011
By
Princeton Environmental Group, Inc.
1120 Chester Avenue, Cleveland, Ohio 44114
Tel: 718-767-7271 Fax: 718-767-7187
Web: www.princetonenvironmental.com
Foreword
Mid 2007, Princeton Environmental Group was given the opportunity to its proprietary
waste to energy process engineering including the patented gasification technology to
Department of Public Power & Utility of City of Cleveland. After 2 years of
investigation, City of Cleveland awarded Princeton with this MSWE Conceptual Design
Contract to convert the City owned Ridge Road Transfer Station to a comprehensive
waste to energy plant.
The Basis of Design of this Municipal Solid Waste to Energy (MSWE) Project
summarizes the criteria that the design work is based upon. This Basis of Design is a
dynamic document that will continue to be updated as the design progresses and
changes. The Basis of Design was prepared in conjunction with the scope of work
defined in the MSWE Scope of Work dated March 30
th
, 2010.
This document is divided into 2 Tasks, Permitting and Basis of Design and each is
listed in accordance to the Scope of Work Time Line as shown below:
Task IV: Permitting
Section 1: Detailed Permit Analysis and Air Permit Application
(A) Permit Analysis
The most important consideration in the facility design is the environmental impact this
facility may impose onto its immediate and surrounding communities and these impacts
are also directly related to the ability of the facility permitting.
The most critical environmental permitting is the stack emission permit, in fact, the entire
facility design from material management to power generation is based on the ability to
receive air emission permit which has to be applied under the regulation and ruling of
Ohio State and US Federal EPA.
This proposed facility is to designed not just for City of Cleveland but also an operating
model to be installed nationwide. Therefore, the air borne impurities control process was
designed not just for permit application but with the best possible status can be achieved
by selected technologies.
The following are the facility and equipment design summaries of air permit application
submitted to Ohio EPA on March 19
th
, 2011 which shall provide the facility layout,
gasification system design and air emission level in comparison with existing N.E. Ohio
level,
Cleveland Public Power Ridge Road MSW Gasification HRSG Project
Overview of Air Permit Application and Basis for Approval
Steering Committee Meeting Tuesday, March 8, 2011
Criteria for Approval of the Air Permit Application:
(1)The proposed project must be equipped with the Best Available Technology (BAT)
for air pollutant emissions control; and
(2) The emissions from the project must result in acceptable air quality impact.
General Project Description:
Best Available Technology (BAT) for Emissions Control:
Emission Control Systems and BAT Summary
Emissions Unit(s)
BAT Emission
Control Technology Pollutant(s) Controlled
Stack Emission
Rate(s)
MSW
Pre-Processing
Localized capture and baghouses
venting inside the building with
water mists (if needed) at building
doorways
Filterable PM/PM
10
/PM
2.5
NA
Gasifier Lines
No. 1 No. 4
Sorbent Injection
(Lime and/or Activiated Carbon)
as needed
Hg and acid gases NA
Baghouse
PM/PM
10
/PM
2.5
and Metal HAPs
PM/PM
10
/PM
2.5
=
6.22 lb/hr
(2)
Selective Catalytic Reduction
(SCR)
NO
x
/NO
2
NO
x
=
15.51 lb/hr
Wet-Flue Gas Desulfurization
(Wet-FGD)
SO
2
, H
2
SO
4
, HCl, HF, other
acid gases and
PM/PM
10
/PM
2.5
SO
2
=
6.19 lb/hr
Combustion Controls CO and VOC
CO =
6.94 lb/hr
VOC =
2.10 lb/hr
Sorbent/Reagent
Storage
Baghouses integral to the
operation of storage silos and
pneumatic transfer of materials
Filterable PM/PM
10
/PM
2.5
NA
Residuals Storage
and Load-Out
Baghouses integral to the
operation of storage silos and
pneumatic transfer of materials
Filterable PM/PM
10
/PM
2.5
NA
Maximum Annual Emissions
Proposed CPP Facility vs Major Stationary Source Thresholds
Air Pollutant
Maximum
Annual Emissions
from CPP Facility
(TPY)
Cuyahoga County
NSR Major Source Threshold
(TPY)
Attainment
PSD
Non-Attainment
NNSR
PM
2.5
(Particulate Matter less than or equal to 2.5
microns in diameter)
99.8 <100
Sulfur Dioxide (SO
2
) (Precursor to PM
2.5
) 99.4 <100
PM
10
(Particulate Matter less than or equal to 10
microns in diameter)
99.8 <250
Sulfur Dioxide (SO
2
) 99.4 <250
Nitrogen Dioxide (NO
2
) 186.8 <250
Nitrogen Oxides (NO
x
) (Precursor to Ozone) 249.0 <250
Volatile Organic Compounds (VOC)
(Precursor to Ozone)
33.75 <250
Carbon Monoxide (CO) 111.5 <250
Lead (Pb) 0.25 <250
CPP Proposed BAT Emission Limitations
vs Other Benchmark Rules and Recent Ohio EPA BAT Determinations
Pollutant
NSPS
Subpart Eb
NSPS
Subpart AAAA
Ohio EPA BAT
Mahoning Energy Permit CPP Proposed BAT
mg/m
3
ppm mg/m
3
ppm mg/m
3
ppm lb/mmBtu mg/m
3
ppm lb/mmBtu
PM 20 24 20 20
SO
2
30 30 24 19.5
NO
x
150 150 75 68
CO 50 50 50 50
HCl 25 25 25 2.9
Dioxin 1.30E-05 1.30E-05 1.30E-05 1.30E-05
Lead 0.14 0.2 0.14 0.14
Cadmium 0.01 0.02 0.01 0.01
Mercury 0.05 0.08 0.05 0.05
Ammonia 15 15
H
2
SO
4 2 1.2
HF 0.5 0.5
VOC 0.026 0.026
Air Quality Impact:
Air quality modeling predicted maximum off-site concentrations at 2,500 receptor locations extending from
the boundary of the Ridge Road site to a distance of more than one mile from the site. The model
predicted hourly average pollutant concentrations for each hour of a five year period (43,800 hours). The
maximum predicted air quality impact for the CPP project is generally less than 50% of the levels
determined to be acceptable by Ohio EPA.
Maximum Predicted Off-Site Air Quality Impacts from
the Proposed CPP Facility vs Ohio EPAs Acceptable Impacts
Pollutant
Maximum
Predicted
Off-Site Impact
ug/m
3
)
Ohio
Acceptable
Impact
(ug/m
3
)
CPP Project
% of
Acceptable
PM
2.5
Annual Average 5.7 15 38%
PM
2.5
24-Hr Average 19.8 35 56%
PM
10
24-Hr Average 7.6 15 51%
SO
2
1-hr Average 44.6 197 23%
SO
2
Annual Average 5.8 10 58%
SO
2
24-Hr Average 21.2 45.5 47%
NO
2
1-Hr Average 79.7 188 42%
NO
2
Annual Average 11.3 12.5 90%
CO 1-Hr Average 61.1 10,000 1%
CO 8-Hr Average 30.25 2,500 1%
HCl 1-Hr Average 5.1 2,199 0%
H
2
SO
4
1-Hr Average 5.6 200 3%
Mercury 1-Hr Average 0.05 10 1%
Dioxin 1-Hr Average 0.0000138 0.002 1%
With these designs, the environmental impact by the proposed Ridge Road Transfer
Station is minimal and the emission levels of many critical impurities are much lower
than the major emission threshold established by Ohio EPA.
The 512 tons/day MSWE power plant to be located at Ridge Road Transfer Station
is being applied as a fixed site minor emission source.
The following tables will demonstrate the proposed Ridge Road MSWE power plant
emission level comparison with (1) Ohio EPA requirements; (2) other facilities in N.E.
Ohio and the air quality impact to the N.E Ohio region,
Table 1
Maximum Potential Emissions from the CPP Facility vs Actual Reported CY 2009
Emissions from Operating Major Industrial and Utility Sources
7
County
NAAQS Air Contaminants
(tons of actual CY 2009 emissions reported by major sources)
VOC NO
x
SO
2
PM
(cond)
PM
(filt) CO
Lead
(Pb) Total
Ashtabula County 3,056 1,245 4,833 148 230 59,995 0.02 69,507
Cuyahoga County 973 2,296 5,684 142 776 6,402 2.6 16,276
Geauga County 18 10 6 NR 9 NR 0.004 43
Lake County 196 7,800 52,030 2,839 498 1,494 0.15 64,857
Lorain County 584 5,655 37,608 499 773 826 4.2 45,949
Medina County 174 75 57 16 34 88 0.004 444
Portage County 359 101 24 8 71 148 0.001 711
Summit County 378 426 2,153 18 107 310 0.39 3,392
NE Ohio Total 5,739 17,607 102,394 3,671 5,678 69,264 7.34 204,360
CPP Ridge Road Potential
NAAQS Emissions (TPY)
34 187 99 64 36 112 0.25 532
CPP Ridge Road Project
% of NE Ohio Major Sources
0.59% 1.06% 0.10% 1.74% 0.63% 0.16% 3.4% 0.26%
NR = None Reported by Major Sources
Table 2
Maximum Potential Emissions from the CPP Facility vs the Ozone and PM
2.5
SIP
Inventories for Sources in NE Ohio
9
Source Category
Emissions from Ozone and PM
2.5
SIP Inventories (tons)
VOC NO
x
PM
2.5 SO
2
Total
Major Industrial 3,853 4,796 862 17,760 27,271
Utility 258 23,905 2,158 91,065 117,386
Area 37,045 10,982 1,643 942 50,612
Non-Road 23,710 15,960 787 284 40,741
Marine 443 6,478 52 767 7,740
Mobile 18,512 48,068 596 362 67,538
Total 86,224 113,040 6,352 112,709 318,325
CPP Ridge Road Potential
Emissions (TPY)
34 187 99.8 99 320.8
CPP Ridge Road Project
% of NE Ohio Major Sources
0.04% 0.03% 1.57% 0.09% 0.10%
Table 3
Maximum Potential VOC Emissions from the CPP Facility vs Actual Reported CY 2009
VOC Emissions from Operating Major Industrial and Utility Sources
7
Major Industrial/Utility Facility City County
CY 2009
VOC (tons)
Ford Motor Company - Ohio Assembly Plant Avon Lake Lorain 258
North Coast Container Cleveland Cuyahoga 121
Morgan Adhesives Company (MACtac) Stow Summit 90
Alfred Nickles Bakery Inc. Navarre Stark 62
Molded Fiber Glass Companies, Plant 2 Ashtabula Ashtabula 59
Plasti-Kote Co., Inc. Medina Medina 56
Joseph Adams Corp. Valley City Medina 50
Avery Dennison Painesville Lake 48
Pechiney Plastic Packaging Inc Akron Summit 47
Automated Packaging Systems Garfield Heights Cuyahoga 37
PPG Industries, Inc. - Cleveland Cleveland Cuyahoga 35
The Lubrizol Corporation - Wickliffe Facility Wickliffe Lake 34
CPP Ridge Road Potential VOC Emissions (TPY) 34
Heritage Fireplace Equipment Co. Akron Summit 28
Graphic Packaging International, Inc. Solon Cuyahoga 24
Table 4
Maximum Potential NO
x
Emissions from the CPP Facility vs Actual Reported CY 2009
NO
x
7
CY 2009
NO
x
(tons)
CEI Eastlake Eastlake Lake 7,055
RRI Energy Avon Lake Power Plant Avon Lake Lorain 5,113
FirstEnergy Ashtabula Plant Ashtabula Ashtabula 991
ArcelorMittal Cleveland Inc. Cleveland Cuyahoga 635
Painesville Municipal Electric Plant Painesville Lake 531
CEI Lake Shore Plant Cleveland Cuyahoga 418
Cleveland Thermal LLC Cleveland Cuyahoga 248
Cargill, Incorporated - Salt Division Akron Summit 230
Millennium Inorganic Chemicals, Inc. Ashtabula Ashtabula 224
CPP Ridge Road Potential NO
x
Emissions (TPY) 187
The Medical Center Company Cleveland Cuyahoga 184
The Lubrizol Corporation Painesville Lake 162
Ross Incineration Services, Inc. Grafton Lorain 155
Ferro Corporation Cleveland Frit Plant Cleveland Cuyahoga 149
Lorain County LFG Power Station Oberlin Lorain 139
Southerly Wastewater Treatment Center Cuyahoga Heights Cuyahoga 116
Table 5
Maximum Potential SO
2
Emissions from the CPP Facility vs Actual Reported CY 2009
SO
2
7
CY 2009
SO
2
(tons)
CEI Eastlake Plant Eastlake Lake 48,670
RRI Energy Avon Lake Power Plant Avon Lake Lorain 37,160
FirstEnergy Ashtabula Plant Ashtabula Ashtabula 4,807
Painesville Municipal Electric Plant Painesville Lake 3,337
The Medical Center Company Cleveland Cuyahoga 2,346
Cargill, Incorporated - Salt Division Akron Summit 1,308
CEI Lake Shore Plant Cleveland Cuyahoga 1,071
Cleveland Thermal LLC Cleveland Cuyahoga 1,039
Emerald Performance Materials, LLC Akron Summit 842
DiGeronimo Aggregates LLC Independence Cuyahoga 427
Oberlin College Oberlin Lorain 403
CPP Ridge Road Potential SO
2
Emissions (TPY) 99
Owens Corning Roofing and Asphalt, LLC Medina Medina 56
Table 6
Maximum Potential Total PM (F + C) Emissions from the CPP Facility vs Actual Reported
CY 2009 Total PM (F + C) Emissions from Operating Major Industrial and Utility Sources
7
CY 2009
PM (F + C)
(tons)
CEI Eastlake Plant Eastlake Lake 3,121
RRI Energy Avon Lake Power Plant Avon Lake Lorain 824
FirstEnergy Ashtabula Plant Ashtabula Ashtabula 255
Painesville Municipal Electric Plant Painesville Lake 167
Elyria Foundry Elyria Lorain 163
Lorain Tubular Company LLC Lorain Lorain 100
CPP Ridge Road Potential Total PM (F + C) Emissions (TPY) 99
CEI Lake Shore Plant Cleveland Cuyahoga 84
Cleveland Thermal LLC Cleveland Cuyahoga 73
Cargill, Incorporated - Salt Division Akron Summit 62
The Medical Center Company Cleveland Cuyahoga 29
Table 7
Maximum Potential Total HAP and Air Toxic Emissions from the CPP Facility vs Actual
Reported CY 2009 Total HAP and Air Toxic Emissions from Operating Sources
County
Total of All Air Toxic and HAP Contaminants
(tons of actual CY 2009 emissions reported)
Ashtabula County 3,085
Cuyahoga County 272
Geauga County 24
Lake County 1,652
Lorain County 1,264
Medina County 96
Portage County 34
Summit County 654
NE Ohio Total 7,083
CPP Ridge Road Potential Total of All
HAP and Air Toxic Emissions (TPY)
39
CPP Ridge Road Project % of NE Ohio
Sources
0.55%
Table 8
Maximum Potential HAP and Air Toxic Emissions from the CPP Facility vs Actual
Reported CY 2009 HAP and Air Toxic Emissions from Operating Sources
County
Ohio EPA Air Toxic
Contaminants US EPA Hazardous Air Pollutants (HAPs)
Ammonia
(NH
3
)
(tons)
Sulfuric
Acid
(H
2
SO
4
)
(tons)
Hydrogen
Chloride
(HCl)
(tons)
Hydrogen
Fluoride
(HF)
(tons)
Cadmiu
m
(Cd)
(lbs)
Mercury
(Hg)
(lbs)
Dioxin
(lbs)
Ashtabula County NR 21.4 122 12 NR 437 NR
Cuyahoga County 79 2.2 7 3 20 13 NR
Geauga County NR NR NR NR NR NR NR
Lake County 6 189.6 1,211 111 NR 275 1
Lorain County 21 103.5 864 82 NR 383 2
Medina County 19 NR 32 NR NR NR NR
Portage County 1 NR NR NR NR 53 NR
Summit County 6 NR 62 NR NR NR NR
NE Ohio Total 132 316.7 2,298 208 20 1,161 3
CPP Ridge Road
Potential Emissions
(TPY)
20.33 9.37 8.42 0.80 40 180 0.05
NR = None Reported
Table 9
Estimated Net Reduction in Annual Greenhouse Gas (CO
2e
) Emissions
from the Operation of the Proposed CPP Facility
CO
2e
Netting 2011 - 2030 2031 - 2060
Estimated CO
2e
Emissions from the CPP Project 210,00 210,000
Estimated CO
2e
Reductions:
(1) Reduced CO
2e
from transportation to the landfill 3,665 3,665
(2) Reduced CO
2e
emissions at landfill 319,312 68,965
(3) Reduced CO
2e
from coal-fired power generation 267,580 267,580
Total Estimated CO
2e
Reductions 590,556 340,210
Net Change in Annual CO
2e
Emissions -380,556 -130,210
Reference Note
1
The information and data in this comparison report were obtained from the Ohio
Environmental Protection Agency (Ohio EPA) Division of Air Pollution Control (DAPC)
web site at: http://www.epa.ohio.gov/Default.aspx?alias=www.epa.ohio.gov/dapc and the
Permit-to-Install (PTI) application filed by the City of Cleveland for the Ridge Road
project on March 11, 2011.
1
Northeast Ohio (NE Ohio) includes the eight-county area identified by US EPA and Ohio
EPA for State Implementation Plan (SIP) development for ozone (i.e., Ashtabula,
Cuyahoga, Geauga, Lake, Lorain, Medina, Portage and Summit Counties). The
evaluation of air pollution control strategies for the ozone NAAQS is based on air quality
modeling that includes volatile organic compound (VOC) and nitrogen oxides (NO
x
)
emissions from major industrial and utility sources, area sources (i.e., minor sources) and
mobile sources (e.g., automobiles, trucks, airplane and marine) located throughout this
eight-county area. The inclusion of all of these sources over a wide geographic area is
necessary because of the distance the air contaminants are transported and the
photochemical reactions that occur over time.
1
The CY 2009 Emissions Inventory can be obtained at:
http://www.epa.ohio.gov/dapc/aqmp/eiu/data.aspx.
1
The CY 2009 Toxic Release Inventory can be obtained at:
http://www.epa.ohio.gov/dapc/tri/reptsdb.aspx.
1
The ozone emission inventory (i.e., inventories for volatile organic compounds (VOC)
and nitrogen oxides (NO
x
) emissions) can be obtained at:
http://www.epa.ohio.gov/portals/27/SIP/eis/Table_3_-_2009_oz_nonattain_area.pdf and
the PM2.5 emission inventory can be obtained at:
http://www.epa.ohio.gov/portals/27/SIP/eis/Tables_8_Appendix_A.pdf.
1
The NAAQS are set at levels determined by the US EPA to be necessary to protect the
most sensitive persons from the adverse effects of air pollution and are found at:
http://epa.gov/air/criteria.html.
1
The original HAPs designated in the federal Clean Air Act are identified at:
http://www.epa.gov/ttn/atw/orig189.html with modifications to this list found at:
http://www.epa.gov/ttn/atw/pollutants/atwsmod.html.
1
The Ohio air toxic pollutants are identified at:
http://www.epa.ohio.gov/portals/27/regs/3745-114/3745-114-01f.pdf.
1
The Greenhouse Gases designated by US EPA are found at:
http://www.epa.gov/climatechange/emissions/downloads09/GHG-MRR-Full%20Version
.pdf (74 FR 56388 (10/30/2009).
1
The Ohio EPA New Source Review (NSR) rules define the term major source in Ohio
Administrative Code (OAC) rule 3745-31-01 (LLL). A copy of this rule can be obtained
at: http://www.epa.ohio.gov/portals/27/regs/3745-31/3745-31-01f.pdf.
1
The Ohio EPA Title V operating permit rules define the term major source in OAC rule
3745-77-01(X). A copy of this rule can be obtained at:
http://www.epa.ohio.gov/portals/27/regs/3745-77/3745-77-01_Final.pdf.
1
Total particulate matter emissions (i.e., filterable PM + condensable PM or PM (F + C))
is particulate matter that is measured by US EPA Test Method 5 (the filterable particulate
emissions component) plus particulate matter that is measured by US EPA Test Method
202 (the condensable emissions component).
1
Test Method 202 was updated on December 21, 2010 (75 FR 80118). A copy of the
revised Method 202 can be found at:
http://www.gpo.gov/fdsys/pkg/FR-2010-12-21/pdf/2010-30847.pdf.
(B) Air Permit Application
Air permit application was executed by City of Cleveland and was submitted to Ohio EPA
on March 11
th
, 2011.
Section 2: Receipt of Air Permit
It was confirmed by Ohio EPAin July that EPAis in the process of preparing 1
st
draft of
Air Permit for Ridge Road Transfer Station Project. More research is required at this time
on CO2 Emission due to newrulings published by Federal EPAin July, 2011.
Once Ohio EPAcompletes its draft, it is required to post on EPAwebsite for 30 days to
facilitate public comments.
If all moves well, it is estimated that said air permit can be issued in late September or early
October, 2011.
Task II: Basis of Design
Section 1 Waste Study &Data
To design material to energy facility, the first we must do is to understand the material
we need to work with. In late 2009 and early 2010, City of Cleveland has conducted city
waste audit using Ridge Road Transfer Station as the primary receiving point and both
reports showed similar results in material quantity, composition and quality. ( See
EXHIBIT 1).
It is established through the City audit that the daily generated and collected trashes are
divided into following categories,
1) Paper Waste: 24.8% 60% recyclable
2) Plastics Waste: 18.8% 30% recyclable
3) Organic Waste: 37.9% Converted to fuel
4) Ferrous Metal: 4.1% 100% recyclable
5) Non-Ferrous Metal: 1.7% 100% recyclable
6) Glass Waste: 4.1% 100% recyclable
7) C & D Waste: 5% 50% recyclable
8) Multi-Material: 3.2% 0% recyclable
9) Special Care Waste: 0.4% 0% recyclable
Multi-Material 3.2%
Glass 4.1%
Organic Waste 37.9%
Non-Ferrous Metal 1.7%
Special Care 0.1%
Paper 24.8%
Plastics 18.8%
C & D 5%
Ferrous Metal 4.1%
With this proposed MSWE process,
1) All recyclable material will be recycled and packaged separately;
2) The non-recyclable organic waste including plastics, foam, rubber, chemicals and
scrap tires are processed and converted to RDF (Refuse Derived Fuel) in the
pellet form which will be utilized for energy generation;
3) Certain construction waste such as concrete, sand, earth, rocks will be combined
with gasification ash and molded into landscape and construction bricks or
manufactured to be road paving aggregates.
Section 2 City &Regional Regulation &Interpretation
As a waste to energy plant to be located on Ridge Road Transfer Station, additional permits
will be required including and not limited to permit to allowus to utilize waste as fuel,
boiler permits, OSHAregulations, dust control permit, etc.
The following is the research done by GT Environmental, Inc. located in Columbus, OH,
same company working to apply the air permit required by this MSWE project.
Other Environmental Permitting Requirements
Not Addressed by the Pending Air Permit Application
for the Proposed Ridge Road MSW Energy Recovery Facility
Prepared by:
GT Environmental, Inc.
Introduction
This assessment addresses other possible environmental permit requirements for the
proposed Ridge Road Municipal Solid Waste (MSW) Energy Recovery Facility that are
not included in the air Permit-to-Install (PTI) application submitted by the City of
Cleveland on March 11, 2011. This includes other activities that could require a
modification of the air permit and/or require that other non-air environmental permits be
obtained.
Current Transfer Station Operation at the Ridge Road Site
The proposed new MSW Energy Recovery Facility will be constructed at the site of the
City of Clevelands existing Transfer Station at 3727 Ridge Road. Currently, the primary
use of the Ridge Road site is for the transfer of MSW from local haul trucks to long haul
vehicles (trailers). Local haul packer trucks pick up the MSW from residences and
commercial establishments throughout the City of Cleveland and deposit the MSW at the
working floor of the Transfer Station. In addition to the City of Cleveland, there are
numerous other communities in Cuyahoga County that are also using the Ridge Road
facility for the transfer of MSW. Front-end loaders pick up the MSW from the Transfer
Station floor and deposit it into the long-haul trailers. The long haul trailers are used to
transport the MSW to the Noble Road Landfill in Richland County (approximately 65
miles from the Ridge Road site).
The existing Transfer Station is operating pursuant to a solid waste transfer station permit
issued by the Ohio Environmental Protection Agency (Ohio EPA). Permit-to-Install
(PTI) 02-12717 was issued by Ohio EPA on June 28, 1999. The Transfer Station PTI
authorizes a maximum daily processing rate of 3,000 tons of MSW. Currently, the
Transfer Station manages between 900 to 1,500 tons of waste daily.
Cleveland Public Power (CPP) has an electrical sub-station at the Ridge Road site that is
used to transform high voltage transmission power to the local distribution network.
This assessment assumes that all of the existing operations are operating pursuant to the
rules and guidelines for environmental permits, plans, etc.
The Proposed New MSW Energy Recovery Facility
The proposed new MSW Energy Recovery Facility will replace the existing Transfer
Station operation with a modern material recovery facility (MRF) and MSW gasification,
combustion and steam turbine generating station. MSW that is delivered to the facility
will be processed through the MRF to maximize the extraction of recyclable materials.
The components of the MSW that are suitable for gasification will be segregated and used
as feedstock to one of the MSW gasification lines. The air PTI application submitted for
the new MSW Energy Recovery Facility identifies the MRF equipment as exempt from air
permit requirements based on the de minimis emissions exemption in Ohio Administrative
Code (OAC) rule 3745-15-05. Dust emissions from the operation of the equipment will
be well controlled and be discharged within the MRF building. The building will be under
negative pressure (i.e., air will not be discharged from this building to the atmosphere)
and it is not expected to release dust or odors to the atmosphere.
The air PTI application submitted for the proposed new MSW energy recovery facility
includes four MSW gasifyer/furnace/heat recovery steam generator (HRSG) lines. Each
line will be equipped with an air pollution control system that includes a filter bag-house,
selective catalytic reduction (SCR) and wet-flue gas desulfurization system (wet-FGD).
The storage of materials that are needed for the operation of the air pollution control
equipment (e.g., reagents such as limestone) will be within silos or other structures that the
air permit application identifies as exempt pursuant to either OAC rule 3745-15-05 or OAC
rule 3745-31-03. Likewise, the by-product materials from the operation of the gasifyers
(ash), the filter bag-house (fly-ash), and the wet-FGD (gypsum-like by-product) will be
stored in silos prior to re-use or transport off-site for disposal. Each of these by-product
materials must be analyzed to determine eligibility for re-use and/or the appropriate
category for waste disposal.
Other Air Permit Requirements
Any physical change or change in the method of operation of the proposed new MSW
Energy Recovery Facility must be evaluated to determine if an air permit is required for the
change and/or if the original air permit must be modified. The air permit application
submitted on March 11, 2011 identified MSW syngas and natural gas as the fuels that will
be combusted at the facility. The introduction of any non-MSW waste to the gasification
process could trigger the requirement for a permit modification and additional air
regulatory requirements.
There are also new activities/changes that could trigger a modification of the air PTI.
These include any change that introduces a new raw material or requires the installation of
a new piece of equipment that: (a) causes air contaminant emissions above what is allowed
in the air PTI for the facility; and/or (b) causes emissions not previously authorized in
amounts that exceed the de minimis emissions thresholds. Examples include the
installation of a supplemental gas-fired boiler or air heaters. Other examples include the
installation of unenclosed or partially enclosed storage piles or material processing
equipment that is not installed/operated within the MRF building. Many physical changes
are likely to be exempt from air permit requirements, however.
Any change that increases the total annual air contaminant emissions from the new MSW
Energy Recovery Facility project must be evaluated to confirm that the facility is a minor
source pursuant to the federal and state New Source Review (NSR) program.
Other Non-Air Environmental Permit Requirements
Solid Waste Permit. Ohio EPAs solid waste rules require that a solid waste PTI be
obtained for the installation and operation of any new solid waste energy recovery facility.
The proposed new MSW Energy Recovery Facility is a new energy recovery facility
and, therefore, a solid waste PTI must be obtained.
The solid waste permit requirements are spelled out in OAC rule 3745-27-50 (Contents of
the Application) and OAC rule 3745-27-51 (Requirements for Approval). Attachment A
to this assessment is a table that compares the requirements of OAC rule 3745-50 and OAC
rule 3745-51 to the comparable provisions that were addressed in the application submitted
for the Transfer Station in 1999 pursuant to OAC rule 3745-27-21 (Contents of the
Application) and OAC rule 3745-27-22 (Requirements for Approval). In every case, the
requirements for an energy recovery facility are equivalent to or less rigorous than the
requirements for a transfer station. The information summarized in this table support the
conclusion that the issuance of the solid waste PTI for the Transfer Station is an indication
that the proposed new MSW Energy Recovery Facility will qualify for the issuance of a
solid waste permit.
By-Product Management and Waste Management. The by-products from the
operation of the proposed new MSW Energy Recovery Facility must be evaluated and
categorized as eligible for beneficial re-use (e.g., ash made into decorative bricks), solid
waste, special industrial waste or hazardous waste. Each category of waste is subject to
different environmental rules and guidelines. The Resource Conservation and Recovery
Act (RCRA) requirements for storage, transport and disposal will apply to any by-products
that are determined to be a hazardous waste. Including requirements for obtaining a
generator identification, storage for less than 90 days, etc.
Waste Water and Storm Water Permitting. The waste water and storm water permits
that may be required for the project are:
Northeast Ohio Regional Sewer District (NORSD) Pretreatment/Indirect
Discharge Permit;
City of Cleveland sewer connection permit;
Ohio EPA Permit to Install for Indirect Discharges;
NORSD construction storm water permit; and
Ohio EPA NPDES for Storm Water (operations).
NORSD Pretreatment/Indirect Discharge Permit. A Pretreatment Indirect
Discharge Permit will be required from the NORSD. The application for this permit must
demonstrate that the facility will meet the local Title II Pretreatment Standards and the
Federal Categorical Pretreatment standards in 40 CFR 423.17.
City of Cleveland Sewer Connection Permit. A permit is required from the City
of Cleveland before a connection is made to the City sewer system.
Ohio EPA Waste Water Permit to Install. An Ohio EPA waste water PTI is
required if a WWT system needs to be installed. The application must meet the federal
categorical pretreatment standards and the local pretreatment standards for the waste water.
Construction Storm Water Permit (NORSD). A general storm water construction
permit must be obtained prior to commencing construction of the proposed new MSW
Energy Recovery Facility. This will require a storm water pollution prevention plan
(SWPPP) for the control of run-off from the site during the construction period. After the
facility is constructed, storm water from the roof drains, parking areas, etc. must be
properly managed. A storm water permit and SWPPP may be required for the ongoing
operation of the facility.
Ohio EPA NPDES Storm Water Discharge Permit (Operations). Steam electric
power generating is an industrial activity covered by the USEPA and Ohio EPA storm
water programs. Based on available information, there will be no industrial materials and
processes exposed to storm water. Raw materials and by-products will be fully contained
inside silos or other structures that will prevent contact of rain water with these materials.
Ohio EPA and NORSD are the permitting authorities for a storm water permit for the
proposed facility and a state-wide general NPDES permit can be obtained to cover the
operation of the proposed facility.
SARA 311/312 Community Right-to-Know Reporting. It is possible the quantity of
ammonia solution used in the SCR control systems will be greater than the 500 pound
threshold planning quantity (TPQ) that triggers the obligation to prepare and submit the
appropriate community right to know initial notification and a Tier 2 report. The annual
Tier 2 report must be submitted to the State Emergency Response Commission (SERC),
the Cuyahoga County Emergency Management Agency and local Fire Department by
March 1
st
of each year. This reporting is codified in 40 CFR 355 and 370 and required in
ORC 3750.
SARA - 313 Toxic Release Inventory (TRI) Report. Ammonia is listed as a SARA 313
chemical and based on the usage may need to be reported on Form R annually. The other
chemical usage at the proposed facility (e.g., boiler cleaning chemicals) will need to be
examined after start-up to determine if any other TRI chemicals are being manufactured,
processed or otherwise used in quantities that trigger the Form R reporting obligation.
The TRI report is due to Ohio EPA and USEPA by July 1
st
each year.
Accidental Release Prevention (CAA 112r). Although ammonia solution will be used
in the SCR control systems, the ammonia will be produced on demand from urea. As a
result, the Clean Air Act Section 112(r) accidental release prevention requirements are not
expected to be applicable to the proposed new facility.
If the design of the air pollution control system changes and more than 20,000 pounds of a
20% or greater ammonia solution is present on site, the Section 112(r) requirements in 40
CFR Part 68 and OAC Chapter 3745-104 would become applicable and the proposed
facility would be required to develop a Risk Management Plan (RMP) in compliance with
these requirements. 40 CFR 68.150 and OAC 3745-104-38 require that the RMP be
submitted to the USEPA and Ohio EPA no later than the date on which the regulated
substance (ammonia solution) is first present in the process.
Demolition and Contaminated Soil Management. Waste materials produced by site
preparation activities and building demolition must be managed as appropriate pursuant to
Ohios demolition debris, solid waste and/or hazardous waste disposal rules. Although
there are no environmental permit requirements for these disposal activities, all waste
materials must be managed in accordance with the appropriate rules.
Ohio Power Siting Board. A Certificate of Environmental Compatibility and Public
Need must be obtained from the Ohio Power Siting Board (OPSB) before construction can
begin on any major utility facility within the state of Ohio. The Ohio Revised Code
(ORC) defines a major utility facility as: a generating plant of 50 MW or more; an
electric transmission line of 125 kilovolts (kV) or more; or a gas or natural gas transmission
line capable of transporting gas at more than 125 pounds per square inch of pressure.
Since the generating capacity of the proposed new MSW Energy Recovery Facility is less
than 50 MW, a Certificate of Environmental Compatibility and Public Need is not
required.
Attachment A
Ohio EPA Solid Waste Rules
PTI Requirements for an Energy Recovery Facility versus a Transfer Station
22
MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Ridge Road Transfer Station
Application for PTI
(B) The following detail engineering
plans, specifications, and information
for solid waste incinerator or solid
waste energy recovery facilities
shall be shown by means of drawings
and narrative descriptions where
appropriate. Minimum dimensions
of the plan drawings shall be
twenty-four inches by thirty-six
inches.
(B) Plan sheets. The following detail
engineering plans, specifications, and
information for the solid waste
transfer facility shall be shown by
means of drawings and narrative
descriptions where appropriate.
Minimum dimensions of the plan
drawings shall be twenty- four inches
by thirty-six inches.
(B) Plan sheets. The following detail
engineering plans, specifications, and
information for the solid waste
transfer facility shall be shown by
means of drawings and narrative
descriptions where appropriate.
Minimum dimensions of the plan
drawings shall be twenty- four inches
by thirty-six inches.
(1) The detail engineering plan cover
sheet to be numbered sheet 1, shall
contain the following information:
(a) The name of the facility and
identification of the facility as either a
solid waste incinerator facility or a
solid waste energy recovery facility.
(b) The precise geographic location
and boundary of the facility, to be
shown on a 7-1/2 minute USGS
topographic map.
(c) The name, address, and telephone
number of both the applicant and the
facility operator.
(d) The name and address of the
owner(s) of the land used for the
facility.
(e) The name and address of the
person who prepared the plans.
sheet to be numbered sheet 1, shall
contain the following information:
(a) The name of the solid waste
transfer facility.
and boundary of the solid waste
transfer facility, to be shown on a road
map.
(c) The name, address and telephone
number of the applicant for the solid
waste transfer facility.
owner(s) and operator(s) for the solid
waste transfer facility, if different
from the applicant.
(e) The name and address of the
person who prepared the plans.
sheet, numbered sheet 1, contains the
following information:
(a) The name of the solid waste
transfer facility.
and boundary of the facility, is shown
on a 7-1/2 minute USGS topographic
map.
(c) The name, address and telephone
number of the applicant for the solid
waste transfer facility.
owner(s) and operator(s) for the solid
waste transfer facility, if different from
the applicant.
(e) The name and address of the person
who prepared the plans.
(2) Plan drawings, showing the
following items located within the
facility boundary and within five
hundred feet of the facility
boundary, shall contain all
information in paragraphs (B)(2)(a) to
(B)(2)(f) of this rule. Those items
specified in paragraphs (B)(2)(b) to
(B)(2)(f) of this rule shall be
illustrated on a series of plan drawings
which shall be numbered
consecutively: 2A, 2B, 2C, etc. All
information specified in an individual
subheading must be shown on the
same plan sheet. An individual plan
drawing may contain information
specified in more than one individual
subheading. A scale of one inch
equals no greater than one hundred
feet shall be used unless otherwise
specified.
(a) All plan drawings required by
paragraph (B)(2) of this rule shall
(2) Plan drawings, to be numbered
consecutively 2A, 2B, 2C, etc., shall
show the following items located
within the facility boundary and
within five hundred feet of the
facility boundary. A scale of one
inch equals no greater than one
hundred feet shall be used.
paragraph (B)(2) of this rule shall
include the following:
(i) The property lines of all land
owned or leased for the solid waste
transfer facility as determined by a
property survey conducted by a
professional skilled in the appropriate
discipline(s).
(ii) The facility boundary and waste
handling areas.
(iii) All public roads, railroads, and
occupied structures.
(iv) Existing topography showing
vegetation and surface waters of the
(2) Plan drawings, are numbered
consecutively 2A, 2B, 2C, etc., and
show the following items located
within the facility boundary and
within five hundred feet of the
facility boundary. A scale of one
inch equals one hundred feet is used.
paragraph (B)(2) of this rule include
the following:
(i) The property lines of all land owned
or leased for the solid waste transfer
facility as determined by a property
survey conducted by a professional
skilled in the appropriate discipline(s).
(ii) The facility boundary and waste
handling areas.
(iii) All public roads, railroads, and
(iv) Existing topography showing
state, as defined in rule 3745-1-02 of
the Administrative Code, with a
23
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
include those items specified in
paragraph (B)(2)(a) of this rule.
(i) The property lines of all land
owned or leased for the facility as
determined by a property survey
conducted by a professional skilled in
the appropriate discipline(s).
(ii) All public roads, railroads, and
(iii) Existing topography showing
contour interval no greater than five
feet.
(iv) The north arrow.
(b) All existing land uses, zoning
classifications, property owners,
political subdivisions, and
communities.
(c) All existing domiciles.
(d) The limits of the regulatory
floodplain.
(e) National park or recreation areas,
candidate areas for potential inclusion
into the national park system, and any
state park or established state park
purchase areas.
(f) State nature preserves, state
wildlife areas, national and state
scenic rivers, any national wildlife
refuge, special interest areas, research
natural areas in the Wayne national
forest, and state resource waters, cold
water habitats, and exceptional warm
water habitats as classified according
to Chapter 3745-1 of the
Administrative Code.
feet.
(v) The north arrow.
(b) A summary of the site environs
and explanation of how the solid
waste transfer facility will meet the
criteria for permit approval by the
director specified in rules 3745-27-02
and 3745-27-22 of the Administrative
Code.
floodplain.
purchase areas.
wildlife areas, national and state
scenic rivers, any national wildlife
refuge, special interest areas, research
natural areas in the Wayne national
forest, and state resource waters, cold
water habitats, and exceptional warm
water habitats as classified in
accordance with Chapter 3745-1 of
the Administrative Code.
(g) The owner(s) and lessee(s)
corresponding to the property shown
in paragraph (B)(2)(a)(i) of this rule.
feet.
(v) The north arrow.
(b) A summary of the site environs and
explanation of how the solid waste
transfer facility will meet the criteria
for permit approval by the director
specified in rules 3745-27-02 and
3745-27-22 of the Administrative
Code.
floodplain.
purchase areas.
wildlife areas, national and state scenic
rivers, any national wildlife refuge,
special interest areas, research natural
areas in the Wayne national forest, and
state resource waters, cold water
habitats, and exceptional warm water
habitats as classified in accordance
with Chapter 3745-1 of the
(g) The owner(s) and lessee(s)
corresponding to the property shown
in paragraph (B)(2)(a)(i) of this rule.
(3) Plan drawings, showing the
following items located within the
facility and within two hundred fifty
feet of the facility boundary shall
contain all information in paragraphs
(B)(3)(a) to (B)(3)(d) of this rule.
Those items specified in paragraphs
(B)(3)(a) to (B)(3)(d) of this rule shall
be illustrated on a series of plan
drawings which shall be numbered
consecutively: 3A, 3B, 3C, etc. All
items specified in an individual
subheading must be shown on the
same plan drawing, unless otherwise
(3) A plan drawing, to be numbered
sheet 3, shall show the location of all
existing or proposed waste handling
areas and the layout of the leachate
management system, including at a
minimum, drains, piping, storage, and
clean-outs. A scale of one inch
equals no greater than fifty feet shall
be used. [Comment: "Waste
handling area" is defined in rule
Code.]
(3) A plan drawing, numbered sheet 3,
shows the location of all existing or
proposed waste handling areas and the
layout of the leachate management
system, including at a minimum,
drains, piping, storage, and clean-outs.
A scale of one inch equals fifty feet is
used.
24
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
specified. An individual plan
drawing may contain information
specified in more than one individual
subheading. A scale of one inch
equals no greater than fifty feet shall
be used. All plan drawings required
by paragraph (B)(3) of this rule shall
include those items specified in
paragraph (B)(2)(a) of this rule.
(a) The location of all existing or
proposed waste handling areas, areas
designated for recycling activities,
maintenance buildings, weighing
facilities, storage buildings, and other
(b) The location of existing or
proposed utilities, including water,
sewerage and sewage treatment,
electricity, gas, and telephone or other
means of communication, and any
utility company easements on or
bordering the site.
(c) The location of all existing and
proposed fencing, gates, and natural or
other screening on the site. Contour
intervals need not be delineated if
such locations are shown on an aerial
photograph.
(d) Existing and proposed constructed
topography of the site. Contour lines
shall have an interval no greater than
five feet.
(4) Surface water drainage
information within the facility
boundary and within five hundred feet
of the facility boundary shall be on
plan drawings numbered
consecutively 4A, 4B, 4C, etc., shall
plainly indicate the vertical and
horizontal scales used and shall show:
(a) The existing direction of flow and
points of concentration of all surface
waters.
(b) Drainage plans, which show:
(i) Grades.
(ii) Natural swales and streams and
existing or proposed diversion
trenches.
(iii) Any special drainage devices to
be used for control of surface erosion.
25
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
(5) Detail construction and
operational plans showing all facility
operations shall be on plan drawings
numbered consecutively 5A, 5B, 5C,
etc. and shall show the following:
(a) Location of incinerators and any
energy recovery equipment, and waste
feed, ash removal, and air pollution
control systems.
(b) Location of on-site solid waste
handling areas, including areas
designated for recycling activities and
ash handling areas.
(c) Direction of prevailing winds
during each season.
(d) Traffic patterns, including on-site
and access roads.
(e) Cross sections, with an interval of
not less than fifty feet, of all surfaces
and facilities on or in which solid
wastes will be placed prior to or
during handling. Describe the
methods and show the materials
proposed to be utilized for
construction of each surface and
facility on each cross section.
(6) In a permit to install application
subject to paragraph (O) of rule
Code, plan drawings which clearly
delineate all "waste handling areas" as
that term is defined in paragraph (D)
of rule 3745-27-37 of the
Administrative Code and show both
of the following:
(a) The distance between the "waste
handling areas" and the property line
of the premises on which the facility
will be located.
(b) All domiciles, schools, jails and
prisons located within one thousand
feet of the "waste handling areas."
(C) The following information shall
be presented in narrative form in a
report divided according to
paragraphs (C)(1) to (C)(5) of this
rule:
(C) Reports. The following
information shall be presented in
narrative form in a report divided
according to paragraphs (C)(1) to
(C)(5) of this rule:
(C) Reports. The following
information is presented in narrative
form in a report divided according to
paragraphs (C)(1) to (C)(5) of this
rule:
(1) A summary of the site environs
and explanation of how the facility
will meet the criteria for permit
approval by the director specified in
rules 3745-27-02 and 3745-27-51 of
(1) A description of how the waste
handling area floor will meet the
director specified in rule 3745-27-22
of the Administrative Code.
(1) A description of how the waste
handling area floor will meet the
director specified in rule 3745-27-22
of the Administrative Code.
26
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
(2) Any variance or exemption
requests fromthe requirements in rule
3745-27-22, 3745-27-23 or
Code
(2) Any variance or exemption
requests from the requirements in rule
3745-27-22, 3745-27-23 or
Code
(2) For informational purposes only, a
discussion of the following:
(a) The equipment to be used in the
operation and maintenance of the
facility, necessary to evaluate the
requested maximum daily waste
receipt. Such information shall
include, at a minimum:
(i) Types of vehicles that will be used
to deliver, handle, and remove solid
wastes, including ash.
(ii) Performance capabilities, waste
processing rate (if applicable), and
principal specifications of each piece
of powered equipment to be used for
loading, unloading, handling, or
processing of solid wastes, including
charging and ash removal.
(iii) Capacity and type of each
container to be used to store solid
wastes, including ash and recycled
materials, on site.
(b) Proposed hours of operation.
(2) For informational purposes only, a
discussion of the following:
(a) The equipment to be used in the
operation and maintenance of the
facility, necessary to evaluate the
requested maximum daily waste
receipt. Such information shall
include, at a minimum:
(i) Types of vehicles that will be used
to deliver, handle, and remove solid
wastes,
(ii) Performance capabilities,
waste processing rate
and principal specifications of
each piece of
powered equipment to be used
for loading,
unloading, handling, or
processing of solid wastes
(b) Proposed hours of operation.
(3) A discussion of the following
operational information:
(a) Authorized maximum daily waste
receipt, as defined in rule 3745-27-01
of the Administrative Code, requested
for the facility.
(b) Description of all activities to be
performed on the site, including, but
not limited to, unloading, loading,
sorting, handling, storage,
compacting, baling, shredding,
crushing, processing rates and order of
operations, charging and operation,
ash removal procedures, operational
methods used to handle bulky and/or
dusty materials, and any other
processing operations.
(c) Detailed description of the
following:
(i) Methods of unloading waste
material from transportation vehicles
(3) A discussion of the following
operational information:
(a) Authorized maximum daily waste
receipt, as defined in rule 3745-27-01
of the Administrative Code, requested
for the facility.
(b) Description of all activities to be
performed on the site, including, but
not limited to, unloading, loading,
sorting, handling, storage, compacting,
baling, shredding, crushing,
processing rates and order of
operations, charging and operation,
ash removal procedures, operational
methods used to handle bulky and/or
dusty materials, and any other
processing operations.
(c) Detailed description of the
following:
(i) Methods of unloading waste
material from transportation vehicles
27
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
on the site.
(ii) Methods of on-site solid waste
handling, including charging and
handling of the ash. All putrescible
solid wastes received at the facility
shall be incinerated within
twenty-four hours, unless an alternate
incineration schedule has been
approved by the director. All
nonputrescible solid waste shall be
incinerated within the timeframe
specified by the permit.
(iii) Traffic patterns on the site.
(iv) Methods of loading all solid waste
being shipped out, including ash.
(v) Inspection procedures to prevent
accepting wastes that may present
operational problems or wastes that
may not be legally accepted.
(vi) Methods of on-site storage of
solid wastes, including ash.
(d) Detailed discussion of control
measures taken including the
following:
(i) The collection, containment,
removal, and disposal of leachate, and
methods to prevent leachate from
entering surface or ground waters.
(ii) Methods to prevent precipitation,
surface waters, birds, rodents, and
other vectors from reaching solid
wastes on site.
(iii) Measures to control fire,
explosion, dust, odor, scavenging,
erosion, and blowing debris.
(e) General recycling procedures to be
conducted on site, if any.
on the site.
(ii) Methods of on-site solid
waste handling
(iii) Traffic patterns on the site.
(iv) Methods of loading all
solid waste being
shipped out
(d) Detailed discussion of control
measures taken including the
following:
(i) The collection, containment,
removal, and disposal of leachate, and
methods to prevent leachate from
entering surface or ground waters.
(ii) Methods to prevent precipitation,
surface waters, birds, rodents, and
other vectors from reaching solid
wastes on site.
(iii) Measures to control fire,
explosion, dust, odor, scavenging,
erosion, and blowing debris.
28
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
(4) The following plans:
(a) A contingency plan detailing
emergency equipment, procedures,
notification, and remediation for the
following:
(i) Discovery of unauthorized wastes.
(ii) Fire, explosion, and spills.
(iii) Equipment failure.
(iv) Handling, removal, and disposal
of solid wastes if all or part of the
facility should become unavailable for
any reason.
(b) A contingency plan that provides
for written notification to the single or
joint county solid waste management
district in which the facility is located,
and general notification to service area
and customers if all or part of the
facility should become unavailable for
any reason which would affect the
facility's ability to accept solid waste.
(c) Ash management plans that shall
comply with applicable state and
federal requirements regarding the
testing, analysis, and management of
ash.
(d) A "final closure plan" that meets
the minimum requirements for facility
final closure as detailed in rule
Code. The "final closure plan" shall
contain, at a minimum, the following
information:
(i) Schedule and description of the
steps necessary to close the facility as
detailed in rule 3745-27-53 of the
(ii) Name, address, and telephone
number of the person or office to
contact regarding the facility during
the final closure period.
(iii) Financial assurance information
as specified in rule 3745-27-15 of the
(3) For informational purposes only,
the contingency plan detailing
emergency procedures, to address the
following:
(a) Discovery of unauthorized wastes.
(b) Fire, explosion, and spills.
(c) Equipment failure.
(d) If all or part of the transfer facility
should become unavailable for any
reason:
(i) The handling, removal and
disposal of solid wastes.
(ii) The written notification of the
solid waste management district in
which the facility is located, the
appropriate Ohio EPA district office,
and the local health district.
(iii) The general
notification of the
service area and customers.
(3) For informational purposes only,
the contingency plan detailing
emergency procedures, to address the
following:
(a) Discovery of unauthorized wastes.
(b) Fire, explosion, and spills.
(c) Equipment failure.
(d) If all or part of the transfer facility
should become unavailable for any
reason:
(i) The handling, removal and disposal
of solid wastes.
(ii) The written notification of the solid
waste management district in which
the facility is located, the appropriate
Ohio EPA district office, and the local
health district.
(iii) The general notification
of the
service area and customers.
(4) Financial assurance information
and the executed final closure
financial assurance instrument as
specified in rule 3745-27-15 of the
(4) Financial assurance information
and the executed final closure financial
assurance instrument as specified in
rule 3745-27-15 of the Administrative
Code.
(5) All applications shall include the
following:
(a) Copies of letters of intent with
(5) All applications shall include the
following:
(5) Application includes the following:
copies of certified mail receipts. These
29
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
copies of certified mail receipts. These
letters of intent shall describe the
intended establishment or
modification of a solid waste
incinerator or solid waste energy
recovery facility, including a
description of property and facility
boundaries, and shall be sent via
certified mail to the following entities:
(i) The governments of the general
purpose political subdivisions where
the facility is situated, i.e., county
commissioners, legislative authority
of a municipal corporation, or the
board of township trustees.
(ii) The single or joint county solid
the facility is located.
(iii) The owner or lessee of any
easement or right of way bordering or
within the proposed facility
boundaries which may be affected by
the proposed solid waste facility.
(iv) The local zoning authority having
jurisdiction, if any.
(v) The local air pollution planning
authority having jurisdiction, if any.
(vi) Park system administrator, if any
part of the facility is located within or
shares the park boundary.
(vii) The conservancy district, if any
shares the conservancy district
boundary.
(viii) The fire department having
responsibility for providing fire
control services where the facility is
located.
(b) Proof of property ownership or
lease agreement to use the property.
(c) A notarized statement that, to the
best of the knowledge of the applicant,
the detail engineering plans,
specifications, and information in the
permit application are true and
accurate.
copies of certified mail receipts.
These letters of intent shall describe
the intended establishment or
modification of a solid waste transfer
facility, and include a description of
property and facility boundaries, and
shall be sent via certified mail to the
following entities:
commissioners, legislative authority
of a municipal corporation, or the
board of township trustees.
the proposed solid waste transfer
facility.
(v) The park system administrator, if
any part of the facility is located
within or shares the park boundary.
(vi) The conservancy district, if any
boundary.
(vii) The fire department having
located.
(viii) The division of air pollution
control and the division of water
pollution control of Ohio EPA,
including a written request for
information pertaining to any
regulatory requirements under
Chapter 3704. or Chapter 6111. of the
Revised Code.
(b) Letters of acknowledgement from
the owners of all parcels of land to be
used for the solid waste transfer
facility.
best of the applicant's knowledge, the
detail engineering plans,
letters of intent describe the intended
establishment or modification of a
solid waste transfer facility, and
include a description of property and
facility boundaries, and were sent via
certified mail to the following entities:
commissioners, legislative authority of
a municipal corporation, or the board
of township trustees.
the proposed solid waste transfer
facility.
(vi) The conservancy district, if any
boundary.
(vii) The fire department having
located.
(viii) The division of air pollution
control and the
division of water pollution
control of Ohio EPA,
including a written request for
information pertaining
to any regulatory requirements
under Chapter 3704.
or Chapter 6111. of the Revised
Code.
(v) The local air pollution
planning authority having
(b) Letters of acknowledgement from
the owners of all parcels of land to be
used for the solid waste transfer
30
MSW Incinerator or
OAC Rule 3745-27-50
Transfer Station
OAC Rule 3745-27-21
Application for PTI
accurate.
facility.
best of the applicant's knowledge, the
detail engineering plans,
accurate.
31
MSW Incinerator or
OAC Rule 3745-27-51
Criteria for Approval
Transfer Station
OAC Rule 3745-27-22
Ridge Road Transfer
Station Permit Application
for PTI
(A) The solid waste incinerator or solid
waste energy recovery facility will be
capable of operating in compliance with
Chapters 3704. and 6111. of the Revised
Code; and
(A) The new or modified solid waste
transfer facility will be capable of
operating in compliance with Chapters
3734., 3704., and 6111. of the Revised
Code.
(A) The new or modified solid
waste transfer facility will be
capable of operating in compliance
with Chapters 3734., 3704., and
6111. of the Revised Code.
(B) The solid waste incinerator or solid
waste energy recovery facility will be
capable of being constructed, operated,
and closed in accordance with Chapter
3745-27 of the Administrative Code, and
with the terms and conditions of the
permit; and
(B) The solid waste transfer facility will
be capable of being constructed, operated,
and closed in accordance with Chapter
3745-27 of the Administrative Code, and
with the terms and conditions of the
permit.
(B) The solid waste transfer facility
will be capable of being
constructed, operated, and closed
in accordance with Chapter
3745-27 of the Administrative
Code, and with the terms and
conditions of the permit.
(C) The solid waste incinerator or solid
waste energy recovery facility is not
located in a floodway; and
(C) The waste handling areas of the solid
waste transfer facility are not located in a
regulatory floodplain.
(C) The waste handling areas of the
solid waste transfer facility are not
located in a regulatory floodplain.
(D) The solid waste incinerator or solid
located within two hundred feet of any
surface waters of the state, as defined in
rule 3745-1-02 of the Administrative
Code.
(D) The waste handling areas of the solid
waste transfer facility are not located
within two hundred feet of any surface
waters of the state, as defined in rule
3745-1-02 of the Administrative Code.
(D) The waste handling areas of the
located within two hundred feet of
any surface waters of the state, as
defined in rule 3745-1-02 of the
(E) The applicant and/or person listed as
operator who has previously or is
currently responsible for the
management or operation of one or more
solid waste facilities, has managed or
operated such facility in substantial
compliance with applicable provisions of
Chapters 3704., 3734., and 6111. of the
Revised Code, and any rules and permits
issued thereunder, and has maintained
substantial compliance with all
applicable orders issued by the director,
the environmental board of review, or
courts having jurisdiction in accordance
Administrative Code, in the course of
such previous or current management or
operations. The director may take into
consideration whether substantial
compliance has been maintained with
any applicable order from a board of
health maintaining a program on the
approved list; and
(E) The applicant and/or person listed as
operator who has previously or is
currently responsible for the management
or operation of one or more solid waste
facilities, has managed or operated such
facilities in substantial compliance with
applicable provisions of Chapters 3704.,
3734., 3714., and 6111. of the Revised
Code, and any rules adopted and permits
issued thereunder, and has maintained
substantial compliance with all applicable
orders issued by the director, the
environmental review appeals
commission, or courts having jurisdiction
in accordance with Chapter 3746-13 of the
Administrative Code, in the course of
such previous or current management or
operations. The director may take into
compliance has been maintained with any
applicable order from a board of health
maintaining a program on the approved
list.
(E) The applicant and/or person
listed as operator who has
previously or is currently
responsible for the management or
operation of one or more solid
waste facilities, has managed or
operated such facilities in
substantial compliance with
applicable provisions of Chapters
3704., 3734., 3714., and 6111. of
the Revised Code, and any rules
adopted and permits issued
thereunder, and has maintained
substantial compliance with all
applicable orders issued by the
director, the environmental review
appeals commission, or courts
having jurisdiction in accordance
Administrative Code, in the course
of such previous or current
management or operations. The
director may take into
compliance has been maintained
with any applicable order from a
board of health maintaining a
program on the approved list.
(F) The person or persons listed as
operator of the facility meet the
32
MSW Incinerator or
OAC Rule 3745-27-51
Transfer Station
OAC Rule 3745-27-22
Ridge Road Transfer
for PTI
requirements of division (L) of section
3734.02 of the Revised Code and rules
adopted thereunder; and
requirements of division (L) of section
3734.02 of the Revised Code and rules
adopted thereunder.
requirements of division (L) of
section 3734.02 of the Revised
Code and rules adopted thereunder.
Note: The Ohio EPA has not
instituted training and certification
programs as of this date.
(G) The applicant meets the requirements
of sections 3734.40 to 3734.47 of the
Revised Code and rules adopted
thereunder; and
(G) The applicant meets the requirements
of sections 3734.42 to 3734.44 of the
Revised Code and rules adopted
thereunder.
(G) The management of this
facility will attain, maintain, and
retain the integrity, public
confidence, and trust, and promote
the general public interest as
regulated by ORC 3734.40 to
3734.43. The members and key
employees at this facility will
maintain standards of
professionalism and responsibility.
(H) The applicant has executed an
instrument that meets the criteria
established in rule 3745-27-15 of the
Administrative Code, for providing
financial responsibility for the final
closure of the solid waste incinerator or
solid waste energy recovery facility in
accordance with rule 3745-27-53 of the
Administrative Code; and
established in rule 3745-27-15 of the
Administrative Code, for providing
financial responsibility for the final
closure of the transfer facility in
accordance with rule 3745-27-24 of the
established in rule 3745-27-15
(I) The solid waste incinerator or solid
located in any of the following areas, in
existence on the date of receipt of the
permit to install application by Ohio
EPA:
(1) National park or recreation area; or
(2) Candidate area for potential inclusion
in the national park system; or
(3) State park or established state park
purchase area; or
(4) Any property that lies within the
boundaries of a national park or
recreation area but that has not been
acquired or is not administered by the
secretary of the United States department
of the interior.
If the solid waste incinerator or solid
waste energy recovery facility is located
within a park or recreation area identified
in this paragraph and exclusively
manages wastes generated within the
park or recreation area, this paragraph
shall not apply; and
(I) The solid waste transfer facility is not
located in any of the following areas, in
existence on the date of receipt of the
permit to install application by Ohio EPA:
(1) National park or recreation area.
(2) Candidate area for potential inclusion
in the national park system.
(3) State park or established state park
purchase area.
(4) Any property that lies within the
boundaries of a national park or recreation
area but that has not been acquired or is
not administered by the secretary of the
United States department of the interior.
If the solid waste transfer facility is
located within a park or recreation area
identified in this paragraph and
exclusively manages wastes generated
within the park or recreation area, this
paragraph shall not apply.
(I) The solid waste transfer facility
is not located in any of the
following areas, in existence on the
date of receipt of the permit to
install application by Ohio EPA:
(1) National park or recreation
area.
(2) Candidate area for potential
inclusion in the national park
system.
(3) State park or established state
park purchase area.
(4) Any property that lies within
the boundaries of a national park or
recreation area but that has not
been acquired or is not
administered by the secretary of the
United States department of the
interior.
(J) The solid waste incinerator or solid (J) The waste handling areas of the solid (J) The waste handling areas of the
33
MSW Incinerator or
OAC Rule 3745-27-51
Transfer Station
OAC Rule 3745-27-22
Ridge Road Transfer
for PTI
located within two hundred fifty feet of
the following, which are in existence on
the date of receipt of the permit to install
application by the Ohio EPA:
(1) Areas designated by the Ohio
department of natural resources as either
a state nature preserve, a state wildlife
area, or a state scenic river; or
(2) Areas designated, owned, and
managed by the Ohio historical society
as a
nature preserve; or
(3) Areas designated by the United States
department of the interior as either a
national wildlife refuge or a national
scenic river; or
forest service as either a special interest
area or a research natural area in the
Wayne national forest; or
(5) Surface waters of the state designated
by Ohio EPA as either a state resource
water, a coldwater habitat, or an
exceptional warmwater habitat, as
classified in accordance with Chapter
3745-1 of the Administrative Code.
within five hundred feet of the following,
which are in existence on the date of
receipt of the permit to install application
by Ohio EPA:
department of natural resources as either a
state nature preserve, a state wildlife area,
or a state scenic river.
managed by the Ohio historical society as
a nature preserve.
department of the interior as either a
national wildlife refuge or a national
scenic river.
forest service as either a special interest
area or a research natural area in the
Wayne national forest.
(5) Surface waters of the state designated
by Ohio EPA as either a state resource
water, a coldwater habitat, or an
exceptional warmwater habitat, as
classified in accordance with Chapter
3745-1 of the Administrative Code.
located within five hundred feet of
the following, which are in
existence on the date of receipt of
the permit to install application by
Ohio EPA:
department of natural resources as
either a state nature preserve, a
state wildlife area, or a state scenic
river.
managed by the Ohio historical
society as a nature preserve.
(3) Areas designated by the United
States department of the interior as
either a
national wildlife refuge or a
national scenic river.
(4) Areas designated by the United
States forest service as either a
special interest area or a research
natural area in the Wayne national
forest.
(5) Surface waters of the state
designated by Ohio EPA as either a
state resource water, a coldwater
habitat, or an exceptional
warmwater habitat, as classified in
accordance with Chapter 3745-1 of
(K) All waste handling areas of a solid
waste incinerator or solid waste energy
recovery facility are not located within
two hundred fifty feet of a domicile in
existence on the date the permit to install
application was received by the Ohio
EPA; and
(K) The waste handling areas of the solid
within two hundred fifty feet of a domicile
in existence on the date of receipt of the
permit to install application by Ohio EPA.
(K) The waste handling areas of the
located within two hundred fifty
feet of a domicile in existence on
the date of receipt of the permit to
install application by Ohio EPA.
(L) All waste handling at the solid waste
recovery facility will take place inside
buildings, structures, or other methods of
cover deemed acceptable to the director;
(M) The waste handling floor(s) of the
solid waste incinerator or solid waste
energy recovery facility:
(1) Shall prevent the infiltration of
leachate, and is constructed to prevent
any
unauthorized discharge of leachate from
the facility;
(2) Readily allows wet or dry cleanup
(L) The waste handling floor(s) of the
transfer facility shall:
(1) Prevent the infiltration of leachate,
and is constructed to prevent any
unauthorized discharge of leachate from
the facility.
(2) Readily allow wet or dry cleanup
operations.
(3) Be sloped to direct leachate to
(L) The waste handling floor(s) of
the transfer facility shall:
(1) Prevent the infiltration of
leachate, and is constructed to
prevent any unauthorized
discharge of leachate from the
facility.
(2) Readily allow wet or dry
cleanup operations.
34
MSW Incinerator or
OAC Rule 3745-27-51
Transfer Station
OAC Rule 3745-27-22
Ridge Road Transfer
for PTI
operations;
(3) Is sloped so as to direct leachate to
collection points and the leachate
management system, and will not allow
ponding of liquids;
(4) Is designed to be capable of
withstanding the forces and weights
encountered during normal facility
operations;
(5) Is accessible to annual visual
inspection for cracks and breaks; and
(6) Is constructed with materials and
methods which enable repairs to be
made; and
collection points within the leachate
management system, and will not allow
ponding of leachate.
(4) Be designed to be capable of
withstanding the forces and weights
encountered during normal facility
operations.
(5) Be accessible to visual inspection for
cracks and breaks.
(6) Be constructed with materials and
methods which enable repairs to be made.
(3) Is sloped to direct leachate to
the interior of the building within
the leachate management system,
and will not allow ponding of
leachate from the facility.
(4) Be designed to be capable of
withstanding the forces and
weights encountered during normal
facility operations.
(5) Be accessible to visual
inspection for cracks and breaks.
(6) Be constructed with materials
and methods which enable repairs
to be made.
(N) Adequate collection, management,
and treatment and/or disposal facilities
are provided for leachate. If leachate
conveyance and storage structures are
utilized, they shall:
(1) Be monitored, as required by the
director; and
(2) For storage tanks, be provided with
spill containment; and
(3) For leachate lines, be double cased;
and
(4) For storage structures, have a
capacity sufficient to ensure proper
operation of the facility.
(M) Adequate leachate collection,
management, and treatment and/or
disposal facilities are provided. If leachate
conveyance and storage structures are
utilized, they shall:
(1) Be monitored and inspected, as
required by the director.
(2) For storage tanks and other leachate
handling areas, be provided with spill
containment.
(3) For storage structures, have a capacity
sufficient to ensure proper operation of the
facility.
(M) Leachate is directed by grade
to sanitary sewer inlets. All inlets
will be fitted with appropriate
castings and screens allowing easy
cleaning. No leachate storage
structures will be utilized.
(O) In the case of a permit to install
application for:
(1) A new solid waste incinerator or solid
waste energy recovery facility to also
treat infectious waste for which a
notation authorizing infectious waste
treatment is proposed to be included in
the solid waste incinerator or solid waste
energy recovery facility's license
pursuant to division (B)(3) of section
3734.05 of the Revised Code; or
(2) To modify an existing solid waste
recovery facility, which does not have
authorization to treat infectious waste, to
treat infectious waste for which a
notation authorizing infectious waste
treatment is proposed to be included in
the solid waste incinerator or solid waste
energy recovery facility's license
pursuant to division (B)(3) of section
3734.05 of the Revised Code,
The application satisfies the criteria
specified in paragraph (D)(5) of rule
35
MSW Incinerator or
OAC Rule 3745-27-51
Transfer Station
OAC Rule 3745-27-22
Ridge Road Transfer
for PTI
3745-27-37 of the Administrative Code.
36
SUMMARY
Other Environmental Permitting Requirements
Not Addressed by the Pending Air Permit Application
for the Proposed Ridge Road MSW Energy Recovery Facility
The following table addresses other possible environmental permit requirements for the
proposed Ridge Road Municipal Solid Waste (MSW) Energy Recovery Facility that are
not included in the air Permit-to-Install (PTI) application submitted by the City of
Cleveland on March 11, 2011. This includes other activities that could require a
modification of the air permit and/or require that other non-air environmental permits be
obtained.
Item
Permit Required?
Comments Yes No
Other Air Permit Requirements
(e.g., auxiliary boiler, air heater, MRF
equipment, etc.)
Minor emissions units are likely exempt under the

de minimis emissions exemption.
Every change in specifications and/or new
equipment must be evaluated.
Solid Waste Energy Recovery Permit

Ohio EPA
This is comparable or less stringent than the solid
waste permit for the existing Transfer Station.
By-Product Management and Waste
Management

By-products (e.g., ash) must be evaluated and
properly managed.
Pretreatment/Indirect Discharge Permit
NORSD &
Ohio EPA
Sewer Connection Permit
NORSD &
City
Waste Water PTI

Ohio EPA
Required if pre-treatment is needed prior to
discharge to the sanitary sewer system.
Construction Storm Water Permit

NORSD
Operating Storm Water Permit

Not required unless the final design includes
industrial materials and processes exposed to storm
water.
SARA 3/11/312 Community
Right-to-Know

Reporting is required only if ammonia or other
chemicals present on site will exceed the specified
thresholds.
SARA 313 Form R Toxic Release

Reporting is required only if the annual usage of
ammonia or other chemical will exceed the
specified thresholds.
Accidental Release Prevention 112(r)

Required only if the amount of ammonia present
exceeds applicable thresholds.
Demolition and Contaminated Soil
Management

Waste materials created during construction must
be properly disposed.
Ohio Power Siting Board

Certificate is not required since the facility will
have a generating capability of less than 50 MW.
37
Section 3 Ridge Road Transfer Station Re-Planning
City of Cleveland wishes to redesign and construct the City owned Waste Transfer Station
located at 3727 Ridge Road, Cleveland, OH44144 to achieve following objectives,
1) Eliminate daily collected waste
2) Eliminate waste associated truck traffic
3) Total waste Recycling
4) Generate trash derived electrical power for Citys base load requirements
5) Minimal air borne emission
6) Zero toxic ground leaching
7) Creation of sustainable jobs
8) Creation of technology based industries
9) Growth of local economy
10) Meet Cleveland Sustainability Initiative
The unique advantages of City of Cleveland which enable the City to implement this
project are the following,
1) City owns its utility infrastructure
2) City collects its city trash
3) City owns the transfer station
This facility conceptual design must be able to provide the City with following
performances,
1) Must achieve 99% waste volume reduction
2) Cleanest possible air/ash emission footprint
3) Total waste material recycling
4) Comprehensive waste material re-use
5) Matured and fully commercialized technologies
6) Minimal dependency on fossil fuel consumption
7) Sustainable and adequate financial return for facility
8) Local and regional manufacturing & equipment procurement
9) Job creations & local commerce
10) A foundation of Cleveland based industries and economy
The planning of the Ridge Road Transfer Station will be working with following
principles,
1) Maintain existing operation until facility is completed
2) Maximize usage of existing landsite for maximum performance
3) All critical applications will be performed indoor
4) Zero tolerance on improper odor discharge and waste exposure concerns
5) Multiple revenue streams thru comprehensive re-use of waste
6) Best proven and fully commercialized technologies only to be applied
38
7) Ability to facilitate multiple waste groups on site
8) An iconic model to all waste to energy applications
9) All equipment and technology vendors must establish local operation
10) Creation of a Cleveland based Eco/Energy industries.
To ensure the designed MSWE Plant on Ridge Road Transfer Station to meet above
considerations, planning of this Plant must be able to address following issues,
1) Quantity Incoherence
Municipality Solid Waste (MSW) management is a very difficult job which requires large
amount specialized vehicle and man power. Waste groups collected from day to day can
be in such differences that no one can correctly predict what and how much each day
collections may bring. For instance, City of Cleveland collects her own waste and
delivered to the city transfer station and the daily collected quantity can be anywhere
from 900 tons to 1,500 tons per day with moisture content can be in 30% in summer or
60% when it rained. This poses tremendous difficulties when it comes to facility design
and engineering.
The first issue is how to control this material quantity incoherence.
2) Material Complexity
As each household disposes their waste, material disposed can be of anything and
everything from our daily lives and beyond; food, textiles, clothing, paper, cans, bottles,
grass and trees, oil, paints, chemicals to wood, furniture, scrap tires, plastics and rubber.
Each material contains its own chemical composition and this makes trash to be
extremely complex when it comes to process engineering.
Second issue is how to minimize material inconsistency.
3) Maximum Revenue Potential
For long term survivability of any project, the most important is to provide forecast-able
and sustainable revenues. This project is enhanced with following revenue streams for its
profitability,
a) Recycle Material Sales: Paper, aluminum cans, non-ferrous metal, scrap steel,
glass, plastics, etc.
b) Electricity Power: 15 megawatt per hour for 8200 hours per year.
c) Bricks, Tiles & C & D waste and furnace ash derived end products.
Aggregates:
d) RDF Pellets (Optional): Residual organic waste after recycling are converted to
fuel pellets which can be marketed as coal.
39
4) Low Operation Cost & Fossil Dependency
One of the key considerations for this project planning is to design this facility to be
highly self-sufficient on energy consumption and lower its operating cost to the minimum.
The impact on energy market on this facility shall be very minimal; this facility is
designed with 80% or higher self-reliance on operating fossil fuel needs and if necessary,
it can become total self-reliant on electrical consumptions.
However, the business model of this facility is to provide 100% of its electrical
generation to the grid and purchase its required electrical needs from the grid. So the
facility shall be an energy producer for CPP and also a good customer of CPP. CPP shall
enjoy the maximum benefits from such operation.
5) Benefits to the City
Any such project must provide benefits to the hosting municipality and this is designed
with following benefits:
a) Eliminate daily collected waste and improve city environments
b) Establish a new tax and revenue center
c) Low cost base load power
d) High saving on general and operation budgets
e) Cleveland based new jobs and commerce
f) Cleveland based businesses and economy
g) Investment and cash infusion to the city
6) Air Borne Emission and Ash Leaching
The design of this system was not just to pass the air permit requirement set forth by
Ohio EPA but to establish a new standard so this designed plant can be exported from
Cleveland to the Nation.
For details on air emission footprint, please read Task IV, Section 1.
7) Impact on Road & Traffic
With out-bound waste hauling traffics will be reduced to minimal by this project, MSWE
Plant shall lower the waste related truck traffic substantially from its current operation
and proportionally on local and high road usage. The outbound traffic will be mostly the
recyclable material pickups and deliveries by and to the material buyers.
8) Appearances and Environments
All planned material handling and processing applications of this design shall be conducted
indoor to minimize odor concerns and bird issue. Exterior property shall be constructed
with pleasing appearance to the public.
9) Construction and Facility Assembly
40
Facility construction and equipment assembly are to be performed major U.S. companies
preferably located in the Cleveland Region.
10) Project Financing
In addition to the City planned Pre-Paid Municipal Bond financing method, this project can
be also financed in a public/private partnership thru private financing.
As a private financing, the investment firm can design, build and lease the facility to the
City for a period of 25 years with a fixed annual leasing fee, plus Cleveland Public Power
shall buy the electricity for 25 years with a pre-agreed per kilo watt cost. In this approach,
the private equity firmcan take advantage of the 30%Energy Investment Tax Credit (ITC),
Newmarket tax Credit and all other potential tax incentives, grants which can substantially
reduce the front capital cost by 30-35%. This is an advantage cannot be enjoyed by any
public entity.
Section 4 Technology Identification &Description
The technology approach to this design is MULTI-TECHNOLOGY INTEGRATION.
Waste is complex and of many incoherencies, it is critically important to utilize proper
technology to its pre-targeted material. We believe multi-tech integration is the only key
to success.
Weigh Station
Many weigh station design and equipment can be identified in the market place. The
purpose of this weigh station is to identify the weight of waste material delivered by the
truck every day.
The weigh station is stationary and as each truck approaches, truck must stop completely
to measure the gross weight of the truck and the same truck is to be weighted again on its
way out, so the Plant shall be able to record the quantity of material being delivered each
day.
Waste Receiving, Separation and Sorting:
After the truck is weighted and recorded, truck is to proceed into loading area to unload
their collected waste. Water material will be transported onto conveyer belts and
delivered to the sorting station.
At this station, workers will be stationed on both side of the conveyers and start to
removing recyclables such as glass, plastic bottles, paper, cans, steel. These recyclables
will be sent to the staging area designated for Recycles which will be sorted again and
baled for sale. Bulky items too big for process, undesirable items such as batteries,
arousal shall be removed from the waste stream wither for discard or to be processed
prior to treatment.
41
After manual sorting, material will then be divided into 2 primary groups, wet waste and
dry waste. Dry waste will be going through another automated recycling process through
various sensors, magnets, gravity, weights and appearances identification equipment.
More recyclables will be recovered. Wet waste are mostly food, forest and yard or
restaurant waste and they will be fed into a conversion process (Steam Conversion) and
transformed into a highly valuable Refuse Derived Fuel (RDF) pellets.
With these proceeding, material will be separated into 4 different groups, recyclable, wet
MSW, dry MSW and non-organic waste.
Primary equipment for this part of operation are conveyer systems, sorting stations, waste
material identification sensors, bulk material handling systems, crushers, shredders,
hoppers, trucks, etc. All of these engineering and equipment can be available from
American manufacturers.
Recyclable Waste Separation & Packaging:
A Single stream, co-mingle recyclable waste separation system enhanced with material
baling equipment will be utilized for this operation. This is where all the recyclable
wastes placed onto feeding machinery together and this system will separate them based
on pre-defined specifications and convey each type to its targeted work area to be baled
and put into storage.
On a national average, 30% of daily collected MSW fall into this category and they
represent very huge cash revenue for this facility.
Single Steam, Co-Mingle Recycling System
42
Photo of Recyclables Baled for Pick-up
Material Recovery & Conversion:
After material sorting, removal and recycling, residual MSW shall be divided into 2
streams, Dry Waste and Wet Waste.
Dry waste will be shredded and down sized and then fed into a fully automated material
recovery process to further recycling. With photo sensors, gravity separators, magnets,
wind separators, any remaining recyclable material in the Dry Waste shall be recovered
for baling and the remaining are mostly non-recyclable paper, plastics, scrap tires, wood
waste, forest waste, yard waste (Organic) and mixed with sand and dirt (inorganic).
The organic components will be transported by conveyer to RDF fabrication area; the
in-organic will be delivered to earthen brick manufacturing site.
Wet waste will be conveyed to the steam compression zone for moisture removal, steam
serialization and compression to power like material.
Both dry waste and wet waste powder are mixed together in a compression unit and
formed as pellets which can be used as fuel for gasification and power production or
simply for sale.
Steam Compression
With detailed sorting, residual MSW can be converted to RDF fuel pellets. The average
heat value of clean mass is between 4,000-5,000 BTU/ lb; their moisture content is
normally between 20-60%. Normally Clean MSW will not be considered as a viable fuel.
43
In our proposal, we adopted a technology called Steam Compression where Clean MSW
will be placed into a tumbling metal tube and applied with saturated high heat and steam.
With this technology, Clean Mass will be broken up to power like material with heat
value ranging 6-7,000 BTU/lb and moisture less than 10%.
With good heat content, very little sulfur and low moisture, Clean MSW Bio Mass now
becomes a perfect replacement of coal, especially when it is marketed at about 30%
below normal coal price.
Steam Compression Unit Being Assembled
44
Pictures of Fuel Pellets from Steam Compression
More Photo on Fuel Pellets
45
Fuel Pellets Chemical Composition
Fuel Pellets Lab Test report
46
Gasification + Power Island
Gasification System Functionalities and Capacity
Thermal processing is the most effective method in waste disposal including incineration,
gasification, anaerobic digestion and pyrolysis. All these methods require heat and heat
can be generated by natural gas, liquid fuel, electric furnace and by waste energy. Every
design has its uniqueness and its shortfalls but is our recommendation that gasification is
the technology we must adopt because of its superior performances above all other
technologies;
1) High waste conversion ratio achievable (97% or higher)
2) High waste energy recovery achievable (95% or higher)
3) Super clean air emission by material engineering achievable
4) Zero ground leaching achievable
5) Very Low operating cost achievable
6) 100% electrical load self-reliance achievable
7) 80% or higher fuel self-reliance achievable
8) High net electricity generation achievable
9) Low ash remnant achievable
10) Long system longevity achievable
Trash Incineration is known for its high operating cost and poor air/ash emissions;
anaerobic digestion cannot be properly equipped to handle large quantity of waste
material and targeted waste can be very limited; Pyrolysis is more for carbon recovery,
not for syngas. All these methods are very energy dependent especially when heat is
being generated by plasma arc (super high voltage electric furnace).
To ensure the lowest possible downtime, this plant is planned with 3-4 redundant
gasification systems and 2 power generation islands each with its own steam boiler,
steam turbines and power generators.
47
A Gasification System by Kinsei Sangyo, Japan
Power Island
Steam Boiler + Steam Turbine
Feedstock for gasification system can be RDF fuel pellets generated by the facility itself
which makes the facility to be highly self-sufficient on energy requirement.
After syngas is generated, syngas will be sent to a gas furnace to be processed at 2,000
0
F
- 2,400
0
F for maximum performance and oxidization. Fuel required for this operation is
mainly derived by the waste itself with only minimal auxiliary fuel needed.
Hot gas from furnace will be sent into heat exchanger unit for air to air or air to liquid
conversion producing steam for steam turbine. Steam turbine will then power the
electricity generator for power. Once electrical power is properly conditioned, it will be
sent to the transformer located on site to be submitted to the grid.
It is estimated, with 30% material being recycled at the front end, remaining waste can
generate approximately 15 megawatt per hour for 8,200 hours per year.
This is enough electricity to power over 70,000 household in Cleveland.
48
Ash & Remnants
This facility produces about 3% ash from organic waste and 100% from non-organic
wastes. Normally these materials will be transported and disposed to landfill which
imposes added operating expenses such as tipping fees, labor, handlings, storage and
trucking.
Fully commercialized technology available in japan and also in Spain will work with
gasification ash mixed with construction wastes such as concrete, sand and rocks and
bonded by a patented agent and fabricate these materials to decorative bricks, landscape
bricks, road paving aggregates, roof or other tiles. We call them Earth Bricks
This brick making technology is an air dried, cold molding process which does not
require any heat, or fossil fuel. Even in the winter time, all bricks can be air dried without
heat.
No heat needed, no fuel required, minimal CO2 footprint.
Decorative Bricks & Tiles Produced with Gasification Ash
49
Earth Brick Manufacturing Plant
More Photo on Ash Bricks
50
Earth Bricks Applications in Japan
51
7.0 Air Emission Control
One of the most unique features of Kinsei Gasification Technology is that, thru precision
temperature controls, Kinsei technology suppresses the formation of toxins during
gasification process and produces extremely clean emission.
To ensure our compliance to both Federal and State Environmental Protection Agencies,
additional filtration process and equipment will be utilized so the air emission quality of
this proposed facility will meet regulatory requirements by any State and on any ground.
Please see Task IV for details.
Section 5 Facility Design &Layout
The following are landsite maps and proposed layout.
However, facility design and layout are subject to official requirements by Ohio EPAair
permit.
Conceptual Design on Exterior Appearances
52
Ridge Road Transfer Station Google Map.
Ridge Road Transfer Station Existing Layout.
53
Proposed Facility Layout.
Proposed Rear View
54
Proposed Side View
Gasification SystemLayout
55
More Conceptual Layout
More Conceptual Layout
56
Section 1 Facility Primary Purposes and Performances
The primary functions of this MSWE project are to, through best proven technologies,
work with daily collected waste to achieve the following,
1) Total control of its own waste
2) Install modernized waste collection process
3) Instate citywide recycling program
4) Eliminate landfill expenses associated with the daily generated trash
5) Achieve total waste material recovery
6) Using waste as primary fuel, generates electricity for the city power needs
7) Establish an iconic business model which can be sold nationwide
8) Creating sustainable jobs and commerce for the City
The following performances are the basis of the proposed design set forth by this office,
1) 97% or higher waste elimination
2) Total waste recycling
3) Comprehensive material recovery
4) High energy production
5) Best possible air emission standards
6) Best proven technology integration
7) Improved citywide waste collection process
8) Multiple waste groups processed without separation
9) High job creation
10) Strong financial sustainability.
All designs are to achieve above considerations.
Section 3 Technology Identification and Equipment Design
Municipal Solid Waste (MSW) is very complex in chemical composition; daily quantity
can fluctuate drastically and the material itself can be very incoherent fromday to day.
To achieve the air emissions to the desired level as we submitted to Ohio EPA, multiple
staged material processing becomes necessary to the collected waste. The proposed facility
consists of 4 separate process engineering,
1) Waste separation and sorting
Daily collected waste will be placed onto conveyer belt and go through the working
area where works will be stationed. In this stage, bulky items and cardboard paper
will be removed by manual labor and send to pre-designated work stations for
recycling or processing.
2) Material recycling and recovery
57
After the bulky material has been removed, the rest of waste will be transferred into
a fully automated material separation unit where all material will be identified and
separated to their pre-designated holding stations using sensors such as magnets,
flowddie current flowdetectors, phototronic, weight and gravity separators.
Recyclables will be sent to packaging systems to be baled and ready to be picked up
by buyers and the non-recyclables will be sent to material conversion process.
All these operations will be performed indoor for odor, dust, moisture control and
also to prevent undesired waste dispensing.
3) Material process and conversion after stage 2, the non recyclables will be processed
through steamcompression and converted to solid fuel in pellet form.
This fuel has very lowmoisture (>10%), lowsulfur content (>0.1%) and high heat
value (>7500 BTU/LB) and very consistent
Gasification and Syngas Control
Gasification is thru controlled environments, organic material is converted to
gaseous fuel consisting of mostly COand Hydrogen. This fuel is highly
combustible and can be utilized similar to natural gas. In our facility design, we
utilize this syngas as fuel to the steamboiler producing high temperature, high
pressure steampowering turbine and producing electricity.
This facility is designed to utilize 500 tons of RDF to produce 15 mw/hr of
electricity and net generation is at 80%.
58
4) Gasifyer Ash to Bricks
With a patented process, this facility is designed with a brick making system with
gasifyer ash and C&D waste.
No heat or fuel required for this brick making process and no leaching problem.
Brick Molding System
Section 5 Syngas Process and Power Generation
Syngas process is the key to clean air emission. The control process is introduced in detail
when air permit was submitted. (See Exhibit 2)
Power generation will be provided by steamturbine generator set. The unit is a Siemens
technology based unit.
Section 6 Material Process and FlowDiagram
The front end systemdesign starts from waste receiving to waste fully separated and
processed. Other options can also be available such as waste derived bio diesel and ethanol.
However, our primary goal is to produce electricity
(See Exhibit 3)
59
Section 6 Codes and Standards
The design will be implemented according to CPP Engineering Standards and the
following codes/guides:
Engineering Standards for the City of Cleveland, Division of Public Power
(CPP)
Ohio Department of Natural Resources (ODNR)
Ohio Department of Transportation (ODOT), Construction and Material
Specifications
Ohio Building Code (OBC)
GLUMRB Recommended Standards for Water Works ("10 State
Standards")
American Association of State Highway and Transportation Officials
(AASHTO)
Americans with Disabilities Act (ADA)
American Institute of Architects (AIA)
American Iron and Steel Institute (AISI)
American National Standards Institute (ANSI)
American Society of Civil Engineers (ASCE)
American Society of Testing and Materials (ASTM)
American Water Works Association (AWWA)
Ductile Iron Pipe Research Association (DIPRA)
Occupational Safety and Health Administration (OSHA)
Prepared by:
Peter Tien
Princeton Environmental Group, Inc.
1120 Chester Avenue, Suite 201A
Cleveland, Ohio 44114
Tel: 718-767-7271
Fax: 718-767-7187
Email: peter.tien@princetonenvironmental.com
August 31
st
, 2011
EXHIBIT 1

Wast e Composi t i on St udy as Par t of
The Muni ci pal Sol i d Wast e- t o- Ener gy
( MSWE) Pr oj ect
Summar y of Oct ober 2009 Resul t s

Presented to:

De p a r t me n t o f Pu b l i c Ut i l i t i e s
1300 Lakeside Avenue
Cleveland, OH 44114
(216) 664-3922

Presented by:

S CS E NGI NE E RS
2060 Reading Road
Suite 200
Cincinnati, Ohio 45202
(513) 421-5353

November 23, 2009
File No. 02209027.00

Offices Nationwide
www.scsengineers.com
Wa s t e C o mp o s i t i o n S t u d y a s P a r t o f MS WE P r o j e c t
C i t y o f C l e v e l a n d D e p a r t me n t o f P u b l i c U t i l i t i e s

i
T abl e of Cont e nt s

Section Page

1 Introduction .............................................................................................................................................. 1
2 Approach ................................................................................................................................................. 1
3 Results ....................................................................................................................................................... 2
Residential Waste Composition ........................................................................................................... 2
Manual Rear-Load Trucks ........................................................................................................... 2
Pilot Program Trucks .................................................................................................................... 6
Waste Stream Comparison ................................................................................................................ 10
4 Laboratory Analysis ............................................................................................................................ 11

L i s t o f E x h i b i t s

No. Page

Exhibit 1. Sampling Distribution ................................................................................................................. 2
Exhibit 2. Waste Composition for October 2009 Manual Rear-Load Trucks ................................... 4
Exhibit 3. Major Waste Components Manual Rear-Load Trucks ......................................................... 6
Exhibit 4. Waste Composition for October 2009 Pilot Program Trucks ............................................ 8
Exhibit 5. Major Waste Components Pilot Program Trucks ................................................................ 10
Exhibit 6. Moisture Analyses ..................................................................................................................... 11

Ap p e n d i c e s

Appendix A Summary of Vehicles Targeted for Sampling
Appendix B Description of Waste Categories


1
1 I NTRODUCTI ON
SCS Engineers conducted a municipal solid waste composition study in October 2009 for the
City of Cleveland Department of Public Works. The study, which was conducted during a five-
day period during October 5-9, 2009 at the Ridge Road Transfer Station, aimed to provide
reliable data on the composition of the residential waste stream produced in the City of
Cleveland. The goal is to provide the City with data that can be used to help plan for the
development of a municipal waste-to-energy facility. The October study was the first of a two-
phase waste composition study for the City. The second phase of the waste sampling and
analysis will be conducted in 2010. This report summarizes the data collected during the
October phase of the study.
2 APPROACH
SCS utilized a field crew that consisted of a Crew Chief and an SCS Field Technician. The
Crew Chief oversaw the projects onsite operations and managed the sorting crew. The Field
Technician was responsible for selecting the appropriate trucks to sample with assistance from
Ridge Road Transfer Station personnel. Once a truck was targeted for sampling, it was directed
to a clear portion of the transfer station tipping floor where transfer station personnel selected the
waste sample from a randomly selected portion of the discharged load. The sample was
collected with using a small loader and then dumped into trash cans and weighed to establish an
appropriate sample weight. Appendix A includes a summary of the vehicles that were targeted
for sampling each day of the study.
The sorting crew consisted of seven laborers that hand-sorted each of the 50 samples that were
collected during the five-day sampling period. Samples were sorted and weighed separately,
with the weight of each component recorded (to the nearest 0.1 pound) on a unique field data
sheet, one sheet for each sample. Each laborer was responsible for the sorting and cataloging of
a particular waste category to maintain consistency and accuracy of the sorting protocol. The
waste materials were sorted into 62 different categories in accordance with the Citys
specifications. A description of the various waste categories is included in Appendix B. The
Crew Chief was responsible for quality control of the waste samples to ensure no cross-
contamination.
Refuse samples were designated as originating from either manual rear-load compacting trucks,
or from the Automated Residential Waste Collection Program (Pilot Program). The Pilot
Program is in select areas throughout the City and uses trucks equipped with an automatic or
semi-automatic arm to collect refuse from residents. Residents in the Pilot Program received
sturdy garbage carts for trash and recycling which can be wheeled to the curb. Manual Rear-
Load Trucks collect trash without an automated arm. Trash bags are collected from the curb by
the driver or helper and then deposited in the back of the truck and compacted. Average waste
composition results of the Manual Rear-Load Trucks and Pilot Program Trucks are presented
separately to show differences in the composition of the waste stream. There were 35 samples
collected from Manual Rear-Load trucks and 15 samples collected from Pilot Program trucks.
The City of Cleveland has three truck stations which each collect waste from a different sector of
the City:

2
- Ridge Road Station Trucks from this station collect waste from the western portion of
the City which is subdivided into Districts 110, 120, and 130.
- Glenville Station Trucks from this station collect waste from the near west and
northeast portion of the City which is subdivided into Districts 210, 220 and 230.
- Carr Center Station Trucks this station collect waste from the southeastern portion of
the city which is subdivided into Districts 310, 320, and 330.
Each station also runs its own Pilot Program trucks in their service area. Exhibit 1 summarizes
the number of samples collected from each District in the City of Cleveland.
E x h i b i t 1 . S a mp l i n g Di s t r i b u t i o n
District 110 120 130 Pilot 210 220 230 Pilot 310 320 330 Pilot
# of Samples 4 4 4 5 4 4 3 5 4 4 4 5
Summary of Sampling per District
Ridge Road Station Glenville Station Carr Center Station

3 RESULTS
Fifty samples were collected during the sampling event. The data from Pilot Program and
Manual Rear-Load Trucks has been analyzed separately. Data presented include mean
percentages by weight, standard deviations, and statistical confidence intervals (95 percent
confidence interval). Derivation of this data is as follows:
Mean ( )
n
x X
n
i
i
1
*
1
=
= ;
Standard Deviation (s) =
( )
( )
( ) 1
2
2
n n
n
x
x
; and

Upper/Lower Confidence Interval Limits =
(
|
|
.
|
\
|
n
X
o
* 96 . 1

where: n = number of samples; and
x

= sample percentage.

RE SI DE NT I AL WAST E COMPOSI T I ON
Ma n u a l Re a r - L o a d T r u c k s
As shown in Exhibits 2 and 3, Organic, Paper, and Plastic waste together comprise about 80
percent of the waste stream sampled from Manual Rear-Load trucks. Additional observations
regarding the composition are outlined below:

3
- Organic Waste - Nearly 38 percent of the waste sampled from the Manual Rear-Load
Trucks was organic waste. Of that 38 percent, the textiles category comprised the most
significant portion at about 10 percent of the total waste stream. Other waste types
making up a significant portion of the organic waste were miscellaneous organic (7.2
percent), and food waste (6.6 percent).
- Paper Waste - About 25 percent of the waste stream sampled from the Manual Rear-
Load Trucks was paper waste. Of that 25 percent, non-recyclable paper comprised the
largest portion of the stream at a little over five percent of the total waste stream.
Significant quantities of newspaper/newsprint (4.1 percent), mixed recyclable paper (4.2
percent), corrugated cardboard (4.5 percent) and paperboard (3.9 percent) were also
observed. Recyclable Paper compromised about 19 percent of the total waste stream.
- Plastic Waste - About 19 percent of the waste stream from Manual Rear-Load trucks
was comprised of plastic waste. Of that 10 percent, plastic film comprised the largest
component of the materials by weight (8.4 percent). Other rigid plastics also comprised a
significant portion of the plastic waste (5.1 percent). Recyclable Plastics (#1-7 bottles and
recyclable containers/tubs) compromised about 4.1 percent of the total waste stream.
- Commingled Recyclables - Aluminum Cans/Tins/Foils, Steel/Bi-metal Cans, and Glass
Bottles comprise about 6.3 percent of the total waste stream.
- Miscellaneous Inorganic This category compromised about 2.4 percent of the total
waste stream. A significant portion of this category can be attributed to kitty litter and
vacuum bags.
- Other Construction and Demolition Waste - About one percent of the waste stream
from Manual Rear-Load Trucks was other construction and demolition waste. In this
case a large amount of carpet was in one of the samples and attributed to this category.
- Hazardous Waste With the exception of tires, which were 0.2 percent of the waste
stream, each of Hazardous Waste categories represented less than 0.1 percent of the total
waste stream.


4
E x h i b i t 2 . Wa s t e Co mp o s i t i o n f o r Oc t o b e r 2 0 0 9
Mean Standard 95% Confidence Limits
Material Components Composition Deviation Lower Upper
PAPER
1 Newspaper/Flyers 4.1% 2.8% 3.1% 5.0%
2 Magazines/Catalogs 1.9% 3.6% 0.7% 3.1%
3 Corrugated Cardboard 4.5% 2.4% 3.7% 5.3%
4 Paperboard 3.9% 1.8% 3.3% 4.5%
5 Telephone Books/Directories 0.7% 1.1% 0.3% 1.1%
6 Mixed Paper 4.2% 2.7% 3.3% 5.1%
7 Wallpaper <0.1% <0.1% <0.1% <0.1%
8 Polycoated Paper 0.4% 0.5% 0.2% 0.5%
9 Non-Recyclable Paper 5.1% 2.3% 4.3% 5.8%
Total Paper 24.8%
PLASTIC
10 PET #1 Bottles (<2 Liters) 1.3% 0.7% 1.1% 1.6%
11 Pet #1 Bottles (>2 Liters) 0.7% 0.4% 0.6% 0.8%
12 HDPE #2 Bottles 1.2% 0.6% 1.1% 1.4%
13 #3-#7 Plastic Bottles 0.1% 0.3% <0.1% 0.2%
14 Polystyrene 1.3% 0.7% 1.0% 1.5%
15 Other Recyclable Containers/Tubs 0.7% 0.5% 0.5% 0.8%
16 Film Plastic - Other 8.4% 3.0% 7.4% 9.4%
17 Other Rigid Plastic 5.1% 2.8% 4.2% 6.1%
Total Plastic 18.8%
ORGANIC
18 Food Waste 6.6% 3.6% 5.4% 7.8%
19 Clothing/Linens/Textiles/Leather 9.7% 7.1% 7.4% 12.0%
20 Wood (Land Clearing) 0.3% 1.3% <0.1% 0.7%
21 Leaves and Grass 4.5% 6.6% 2.3% 6.7%
22 Wood (Yard Waste) 1.8% 3.0% 0.8% 2.8%
23 Untreated Lumber/Wood 2.1% 3.1% 1.0% 3.1%
24 Fish Waste <0.1% <0.1% <0.1% <0.1%
25 Diapers & Sanitary Products 3.1% 2.1% 2.4% 3.8%
26 Fines 2.7% 1.3% 2.3% 3.1%
27 Miscellaneous Organics 7.2% 1.1% 6.8% 7.5%
Total Organic 37.9%
FERROUS METAL
28 Ferrous/Bi-metal Cans 1.6% 0.9% 1.3% 1.9%
29 Aerosol <0.1% 0.2% <0.1% 0.1%
30 Empty Paint Cans/Lids 0.1% 0.4% <0.1% 0.3%
31 Other Ferrous 2.3% 4.6% 0.8% 3.8%
Total Ferrous Metal 4.1%


5
Exhibit 2 continued.
NON-FERROUS METAL
32 Aluminum Cans/Tins/Foil 1.3% 0.9% 1.0% 1.6%
33 Aerosol Cans 0.1% 0.2% <0.1% 0.2%
34 Other Aluminum <0.1% <0.1% <0.1% <0.1%
35 Other Non-Ferrous 0.2% 0.4% <0.1% 0.3%
Total Non-Ferrous Metal 1.7%
GLASS
36 Clear Bottles 1.9% 1.5% 1.4% 2.4%
37 Colored Bottles 1.5% 1.3% 1.1% 2.0%
38 Non-Container Glass 0.7% 1.7% 0.2% 1.3%
Total Glass 4.1%
Construction and Demolition Waste
39 Asphalt, Brick, Concrete 0.8% 2.7% <0.1% 1.7%
40 Roofing Shingles <0.1% 0.1% <0.1% <0.1%
41 Drywall/Gypsum Board 0.4% 2.3% <0.1% 1.2%
42 Treated Wood 2.7% 4.9% 1.1% 4.3%
43 Other C&D Waste 1.0% 6.2% <0.1% 3.1%
Total C&D Waste 5.0%
Multi Material Waste
44 Predominantly Paper <0.1% <0.1% <0.1% <0.1%
45 Predominantly Glass <0.1% <0.1% <0.1% <0.1%
46 Predominantly Ferrous 0.5% 2.4% <0.1% 1.3%
47 Predominantly Non-Ferrous <0.1% <0.1% <0.1% <0.1%
48 Predominantly Plastic 0.2% 0.9% <0.1% 0.5%
49 Other Composites 0.2% 0.7% <0.1% 0.4%
50 Misc. Inorganic 2.4% 2.9% 1.5% 3.4%
Total Multi-Material 3.2%
Hazardous/Special Care
51 Lead-Acid Batteries <0.1% <0.1% <0.1% <0.1%
52 Other Rechargeable Batteries <0.1% <0.1% <0.1% <0.1%
53 Other Batteries <0.1% <0.1% <0.1% <0.1%
54 Oil-based Paints/Thinners <0.1% <0.1% <0.1% <0.1%
55 Latex Paints <0.1% 0.2% <0.1% 0.1%
56 Poisons <0.1% <0.1% <0.1% <0.1%
57 Corrosives/Solvents <0.1% <0.1% <0.1% <0.1%
58 Tires 0.2% 0.9% <0.1% 0.5%
59 Medical <0.1% <0.1% <0.1% <0.1%
60 Fuel/Lubricants/Auto <0.1% 0.2% <0.1% 0.1%
61 HW Containers <0.1% 0.3% <0.1% 0.2%
62 Other Hazardous <0.1% <0.1% <0.1% <0.1%
Total Hazardous/Special Care 0.4%
100.0%
Note: Composition based on 35 samples.
TOTALS


6
E x h i b i t 3 . Ma j o r Wa s t e Co mp o n e n t s
Paper
24.8%
FerrousMetal
4.1%
C&D
5.0%
Plastic
18.8%
MultiMaterial
3.2%
Glass
4.1%
Organic
37.9%
Non
Ferrous
Metal
1.7%
Hazard/Special
0.4%

P i l o t P r o g r a m T r u c k s
As shown in Exhibits 4 and 5, Organic, Paper, and Plastic waste together comprise about 80
percent of the waste stream sampled from Pilot Program trucks. Additional observations
regarding the composition are outlined below.
- Organic Waste - Nearly 40 percent of the waste stream from Pilot Program trucks was
comprised of organic wastes. Of that 40 percent, the textiles category comprised the
most significant portion at about nine percent of the total waste stream. Other significant
components of the organic portion of the waste stream include miscellaneous organics
(6.9 percent), and food waste (6.7 percent).
- Paper Waste - Nearly 24 percent of the waste stream consisted of paper materials. Non-
recyclable paper made up the largest portion of paper at 5.5 percent of the entire waste
stream. Significant quantities of newspaper/newsprint (3.9 percent), mixed recyclable
paper (4.5 percent), corrugated cardboard (3.0 percent) and paperboard (4.4 percent) were
also observed. Recyclable Paper compromised about 18 percent of the total waste
stream.
- Plastic Waste - About 19 percent of the waste stream from Pilot Program trucks was
comprised of plastics. Plastic film comprised the largest component of plastic waste by
weight (8.5 percent). Other rigid plastics also composed a significant portion of the
plastic waste (5.6 percent). Recyclable Plastics (#1-7 bottles and recyclable
containers/tubs) compromised about 3.8 percent of the total waste stream.

7
- Commingled Recyclables - Aluminum, Steel/Bi-metal Cans, and Glass Bottles
characterize about 7.6 percent of the total waste stream.
- Miscellaneous. Inorganic This category compromised about 2.5 percent of the total
waste stream. A significant portion of this category can be attributed to Kitty Litter and
vacuum bags.
- Other Construction and Demolition - About 2.6 percent of the waste stream from Pilot
Program trucks was construction and demolition waste. In this case a large amount of
linoleum flooring was in one of the samples and attributed to this category.
- Hazardous - Each of Hazardous Waste categories represented less than 0.1 percent of the
total waste stream, except medical waste (0.4 percent).


8
E x h i b i t 4 . Wa s t e Co mp o s i t i o n f o r Oc t o b e r 2 0 0 9
PAPER
1 Newspaper/Flyers 3.9% 2.5% 2.7% 5.2%
2 Magazines/Catalogs 1.7% 1.2% 1.1% 2.3%
3 Corrugated Cardboard 3.0% 1.7% 2.1% 3.8%
4 Paperboard 4.4% 2.1% 3.4% 5.5%
5 Telephone Books/Directories 0.9% 1.7% <0.1% 1.7%
6 Mixed Paper 4.5% 2.2% 3.3% 5.6%
7 Wallpaper <0.1% <0.1% <0.1% <0.1%
8 Polycoated Paper <0.1% 0.7% <0.1% 0.4%
9 Non-Recyclable Paper 5.5% 3.4% 3.8% 7.2%
Total Paper 23.9%
PLASTIC
10 PET #1 Bottles (<2 Liters) 1.4% 0.7% 1.1% 1.7%
11 Pet #1 Bottles (>2 Liters) 0.5% 0.5% 0.3% 0.8%
12 HDPE #2 Bottles 0.9% 0.4% 0.8% 1.1%
13 #3-#7 Plastic Bottles 0.2% 0.3% <0.1% 0.4%
14 Polystyrene 1.3% 0.8% 0.9% 1.8%
15 Other Recyclable Containers/Tubs 0.7% 0.6% 0.4% 1.0%
16 Film Plastic - Other 8.5% 2.0% 7.5% 9.5%
17 Other Rigid Plastic 5.6% 3.0% 4.0% 7.1%
Total Plastic 19.2%
ORGANIC
18 Food Waste 6.7% 3.3% 5.0% 8.4%
19 Clothing/Linens/Textiles/Leather 8.8% 5.3% 6.2% 11.5%
20 Wood (Land Clearing) <0.1% <0.1% <0.1% <0.1%
21 Leaves and Grass 7.5% 6.7% 4.1% 10.9%
22 Wood (Yard Waste) 1.8% 3.5% <0.1% 3.5%
23 Untreated Lumber/Wood 1.4% 2.1% 0.4% 2.5%
24 Fish Waste <0.1% <0.1% <0.1% <0.1%
25 Diapers & Sanitary Products 3.5% 3.0% 2.0% 5.1%
26 Fines 3.0% 2.5% 1.7% 4.3%
27 Miscellaneous Organics 6.9% 1.3% 6.2% 7.6%
Total Organic 39.7%
FERROUS METAL
28 Ferrous/Bi-metal Cans 2.5% 2.7% 1.2% 3.8%
29 Aerosol 0.2% 0.3% <0.1% 0.4%
30 Empty Paint Cans/Lids <0.1% 0.2% <0.1% 0.2%
31 Other Ferrous 1.0% 0.9% 0.5% 1.5%
Total Ferrous Metal 3.8%


9
Exhibit 4 - continued
NON-FERROUS METAL
32 Aluminum Cans/Tins/Foil 1.7% 1.9% 0.7% 2.6%
33 Aerosol Cans 0.3% 0.3% 0.1% 0.4%
34 Other Aluminum <0.1% <0.1% <0.1% <0.1%
35 Other Non-Ferrous <0.1% 0.8% <0.1% 0.4%
Total Non-Ferrous Metal 2.0%
GLASS
36 Clear Bottles 2.7% 2.2% 1.5% 3.8%
37 Colored Bottles 0.8% 1.0% 0.2% 1.3%
38 Non-Container Glass 0.9% 1.4% 0.2% 1.6%
Total Glass 4.3%
Construction and Demolition Waste
39 Asphalt, Brick, Concrete <0.1% <0.1% <0.1% <0.1%
40 Roofing Shingles <0.1% <0.1% <0.1% <0.1%
41 Drywall/Gypsum Board 0.1% 0.4% <0.1% 0.3%
42 Treated Wood 1.3% 2.9% <0.1% 2.8%
43 Other C&D Waste 1.2% 3.4% <0.1% 2.9%
Total C&D Waste 2.6%
Multi Material Waste
44 Predominantly Paper <0.1% <0.1% <0.1% <0.1%
45 Predominantly Glass <0.1% <0.1% <0.1% <0.1%
46 Predominantly Ferrous 0.9% 2.5% <0.1% 2.2%
47 Predominantly Non-Ferrous <0.1% <0.1% <0.1% <0.1%
48 Predominantly Plastic 0.1% 0.5% <0.1% 0.3%
49 Other Composites 0.4% 1.5% <0.1% 1.2%
50 Misc. Inorganic 2.5% 3.1% 1.0% 4.1%
Total Multi-Material 4.0%
Hazardous/Special Care
51 Lead-Acid Batteries <0.1% <0.1% <0.1% <0.1%
52 Other Rechargeable Batteries <0.1% <0.1% <0.1% <0.1%
53 Other Batteries <0.1% <0.1% <0.1% <0.1%
54 Oil-based Paints/Thinners <0.1% <0.1% <0.1% <0.1%
55 Latex Paints <0.1% 0.2% <0.1% 0.2%
56 Poisons <0.1% <0.1% <0.1% <0.1%
57 Corrosives/Solvents <0.1% <0.1% <0.1% <0.1%
58 Tires <0.1% <0.1% <0.1% <0.1%
59 Medical 0.4% 1.6% <0.1% 1.2%
60 Fuel/Lubricants/Auto <0.1% <0.1% <0.1% <0.1%
61 HW Containers <0.1% 0.1% <0.1% 0.1%
62 Other Hazardous <0.1% <0.1% <0.1% <0.1%
Total Hazardous/Special Care 0.6%
100.0%
Note: Composition based on 15 samples.
TOTALS


1 0
E x h i b i t 5 . Ma j o r Wa s t e Co mp o n e n t s
Paper
23.9%
FerrousMetal
3.8%
C&D
2.6%
Plastic
19.2%
MultiMaterial
4.0%
Glass
4.3%
Organic
39.7%
Non
Ferrous
Metal
2.0%
Hazard/Special
0.6%

WAST E ST RE AM COMPARI SON
For the most part, the samples from the Pilot Program and Manual Rear-Load trucks were
similar. The waste categories for which the 95 percent confidence intervals differ indicate a
statistically significant difference between waste loads from Manual Rear-Load trucks and Pilot
Program trucks. Three waste categories had significantly different proportions of the waste
stream and these are described below.
Corrugated Cardboard There is significantly more corrugated cardboard in waste loads from
Manual Rear-Load trucks than in waste loads from Pilot Program trucks. As can be seen in
Exhibit 2, the 95 percent confidence interval for the Manual Rear-Load trucks is from 3.7
percent to 5.3 percent. This is significantly higher than the confidence interval for Pilot Program
trucks which is from 2.1 percent to 3.8 percent shown in Exhibit 4. This difference can likely be
attributed to residents having a readily accessible recycling container adjacent to their waste
containers.
Plastic HDPE #2 Bottles There is significantly more plastic HDPE #2 bottles in waste loads
from Manual Rear-Load trucks than in waste loads from Pilot Program trucks. The confidence
interval for the Manual Rear-Load trucks is from 1.1 percent to 1.4 percent. The confidence
interval for the Pilot Program trucks is from 0.8 percent to 1.1 percent.
Glass Colored Bottles There is significantly more glass colored bottles in waste loads from
Manual Rear-Load trucks than in waste loads from Pilot Program trucks. The confidence
interval for the Manual Rear-Load trucks is from 1.1 percent to 2.0 percent. The confidence
interval for the Pilot Program trucks is from 0.2 percent to 1.3 percent.

1 1
4 L ABORATORY ANALYSI S
As part of this study, SCS contracted with Test America Laboratories to perform the moisture
analysis of targeted waste samples. The results of the laboratory analysis, including the waste
samples tested and the content tested for, are outlined in Exhibit 6.
E x h i b i t 6 . Mo i s t u r e An a l y s e s
Sample Material Result (% Moisture)
Plastic 26
Misc. Organic 80
Paper 32
Food 89
Textiles 46
Plastic 21
Misc. Organic 42
Paper 37
Food 77
Textiles 13
Plastic 23.5
Misc. Organic 61
Paper 34.5
Food 83
Textiles 29.5
Moisture Analysis (Pilot Trucks)
Moisture Analysis (Manual Rear-Load Trucks)
Average Moisture (Pilot and Manual Rear-Load)

Each test was carried out according to the appropriate U.S. EPA test method. All samples were
received into the laboratory at a temperature of 10 C and the reported results were obtained in
compliance with 2003 National Environmental Laboratory Accreditation Conference standards.

Appendix A

Summary of Vehicles Targeted for Sampling


NUMBEROFSAMPLESBYCOLLECTIONDISTRICT
Monday Tuesday Wednesday Thursday Friday
District110 1 1 1 1
District120 1 1 1 1
District130 1 1 1 1
Pilot 1 1 1 1 1
District210 1 1 1 1
District220 1 1 1 1
District230 1 1 1 1
Pilot 1 1 1 1 1
District310 1 1 1 1
District320 1 1 1
District330 1 1 1 1
Pilot 1 1 1 1 1
TotalSamples 10 10 10 10 10
RidgeRoadStation
GlenvilleStation
CarrCenterStation


Appendix B

Description of Waste Categories


Cleveland Public Power 2009 Waste Stream Analysis

Categories and Definitions
PAPER

1. Newspaper/Newsprint: Consists of all paper products printed on daily or weekly
newspapers, advertising, newsprint catalogs, and other similar items. Includes
any glossy, shiny, or other coated newspaper inserts. Publications can be one
color (e.g., black and white) or multi-color.

2. Magazines: Publications which are printed on glossy paper. This does not
include magazines, glossy catalogs, etc., which do not consist of glossy paper
throughout (e.g., comic books).

3. Corrugated: Paperboard containers consisting of kraft (brown) linerboard with
corrugated (fluted medium) fillings. Excludes waxed corrugated boxes; those
are non-recyclable and should be included as Other Paper.

4. Paperboard: Non-corrugated boxes and containers typically used for holding
food products, detergents, shoes, and other similar packaged goods. Outside of
box or container can be printed. Inside surface is typically a dull gray, brown, or
white color.

5. Telephone Books/ Directories

6. Mixed Recyclable Paper: High-grade paper products originating from an office
environment such as white or colored printing, writing, or copier paper;
computer paper (with or without green bars); computer tab cards; file folders.
Envelopes, junk mail, construction paper, wrapping paper, brochures, kraft
paper, and other recyclable papers.

7. Wallpaper

8. Aseptic/Poly-Coated Food Containers: Consist of plastic or waxed paper
containers such as gable-topped milk and juice cartons, Chinese food take-out
boxes, and juice drink boxes such as those made by Ocean Spray etc.

9. Non-Recyclable Paper: All paper products not covered by the above categories,
including all tissues, paper towels, and napkins, carbon paper, and other non-
recyclable papers.

PLASTICS

10. PET (#l) (Polyethylene Terephthalate) Narrow Neck Bottles (<2 liters): Rigid
clear or colored cylindrical bottles or containers with or without base cups for
holding carbonated soft drinks, cooking oil, mouthwash, liquor, juice, water, and

other food ingredients, etc. The bottom of the bottle or container is coded "1"
and usually has a small dot or nipple, not a seam.

11. 2 Liter PET bottles: Same as above but specific for this size category

12. HDPE (#2) (High Density Polyethylene) Narrow Neck Bottles Natural or
Pigmented: Moderately flexible to stiff cylindrical containers, commonly used
for shampoos, detergents, motor oils, antifreeze, transmission fluids, windshield
washer fluids, cleaning solutions and syrup, milk, juice or spring water products.
The bottom of the container is coded "2" and usually has a seam.

13. #3-#7 Bottles: Rigid, narrow-necked bottles with code 3, 4, 5, or 7 on
the bottom.

14. Polystyrene: Rigid containers with code "6" on the bottom. Includes foamed
polystyrene cups and food service containers (i.e., "clamshells") as well as clear
rigid food service containers and packing "peanuts."

15. Other Plastic Containers/Tubs: Any type of recyclable plastic container (any
number except 6) and tubs not covered by the above categories (i.e., yoghurt
containers, margarine tubs, etc.).

16. Film Plastic: Translucent and opaque films/bags, such as trash, grocery and
garbage bags, dry cleaning film.

17. Other Rigid Plastic (Non-Recyclable): Rigid plastic items such as pens, toys, CD
cases.

ORGANICS

18. Food Waste: Putrescible organic materials which are the by-products of activities
connected with the growing, preparation, cooking, processing, or consumption of
food by human beings or domesticated animals.

19. Clothing/Linens/Textiles/Leather: Apparel and linens made from natural and
synthetic fibers, such as clothing, blankets, sheets, towels, curtains, pillows, rags,
shoes, belts, handbags, stuffed toys, upholstery, and other fabric products.

20. Land Clearing Wood: Large Stumps, logs or branches.

21. Leaves and Grass Trimmings

22. Woody Yard Waste: Smaller diameter branches or trimmings from shrubs and
trees.


23. Untreated Lumber/Wood: Any size of untreated lumber or wood used for
building, such as 2x4s or pallets.

24. Fish Waste: Fish carcasses and leftover food

25. Diapers and Sanitary Products: Disposable diapers, tampons, and sanitary
napkins.

26. Fines: Any materials separated by falling through the sorting table mesh that
cannot be categorized and are less than 0.5 inches in diameter.

27. Miscellaneous Organics: All other organic materials not covered by the above
categories, including feces and dead animals, and organic items too small to sort.

FERROUS

28. Ferrous/Bi-Metal Cans: Steel and bi-metal food and beverage cans.

29. Aerosol Cans: Any empty ferrous Aerosol cans.

30. Paint Cans and Lids: Empty paint cans and lids, any size.

31. Other Ferrous: Ferrous scrap materials such as wire coat hangers, household
appliances, nails and screws, auto parts, and other items adhering to a magnet.

NON- FERROUS

32. Aluminum Cans/Tins/Foil: Aluminum beverage containers, tins, and and foil.

33. Aerosol Cans: Any empty non ferrous Aerosol cans.

34. Other Aluminum: Other aluminum items such as siding, lawn chairs, window
frames, rain gutters, etc.

35. Other Non-ferrous: Non-magnetizable, non-aluminum metals such as silver,
lead, copper, brass, bronze, zinc, stainless steel.

GLASS

36. Clear Glass: Glass bottles used for food and beverages.

37. Colored Glass: Brown, Green or other colored glass bottles used for food and
beverages

38. Other Glass: Glass not used for containers. Includes window glass, drinking
glasses, light bulbs, and dinnerware

CONSTRUCTION AND DEMOLITION

39. Asphalt, Brick, Rock, or Concrete

40. Roofing Shingles

41. Sheetrock/Drywall/Gypsum Board

42. Treated Wood

43. Other C&D

MULTI-MATERIAL OBJECTS

44. Predominantly Paper

45. Predominantly Glass

46. Predominantly Ferrous

47. Predominantly Non-Ferrous

48. Predominantly Plastic

49. Other Composites

50. Misc. Inorganic: Unclassifiable inorganic objects, often kitty litter or the contents
of vacuum bags.

SPECIAL CARE WASTE

Note: The hazardous waste packed with Containers, the weights for both the hazardous
waste and containers must be estimated and reported.

51. Lead Acid Batteries: Lead-acid batteries from automobiles, trucks, buses, boats,
motorcycles, etc.

52. Alkaline Batteries

53. Other Rechargeable Batteries: All rechargeable batteries other than Category
#50, e.g., Ni-Cd, SSLA, Ni-MH, Li-ion, etc.

54. Paints/Thinners: Oil-based paint or thinners and any other flammable liquid
including stains, furniture polish, wood preservatives, and rust proofing agents.


55. Latex Paint

56. Tires

57. Poisons: Any toxic waste items thus marked such as pesticides and insecticides.

58. Corrosives/Solvents: Any toxic waste items thus marked including swimming
pool chemicals, oven cleaner, drain cleaner, and photographic chemicals.

59. Medical: Any item contaminated with blood and other body fluid. Include
syringes, needles, dressings, etc.

60. Fuel/Lubricants/Auto: Any waste item thus marked including motor oil,
transmission fluid, brake fluid and antifreeze.

61. HW Containers: The empty containers for hazardous materials and chemicals.

62. Other Hazardous: Any other hazardous material not otherwise described.

EXHIBIT 2
EXHIBIT 3

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