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CLEVELAND — “When the City of Cleveland notified Peter Tien on February 23, 2012, that he was in default on his $1.5 million no-bid contract to design a garbage incinerator for Cleveland Public Power, Utilities Director Barry Withers’ letter said there were numerous errors in Tien’s reports.
Ohio Citizen Action filed a public records request for copies of Tien’s reports and received several copies of reports on March 9. We still have requests pending for updates that Tien apparently submitted at the end of last week.
Although there were a variety of errors and inconsistencies in Tien’s filings, making all of the numbers suspect, the most damning mistake appears to be a miscalculation of the profit and loss for the facility.
Tien apparently submitted three different versions of his “Design Memorandum” to the city, one dated February 4, one dated February 11, and one dated February 17 (all had the wrong year on them, 2011 rather than 2012).
Tien’s analyses all showed that the facility would make money, with the final document on February 17, showing an annual profit of $4.7 million after covering operating cost and debt service.
But if he had done the math correctly, the February 17 report would have shown the facility losing approximately $17 million per year after operations and debt service.
Here’s the documentation: Continue reading Cleveland incinerator: Consultant gets caught cooking the books
 A proposed waste-to-energy plant would provide some of the electricity supplied by Cleveland Public Power. CLEVELAND — “City officials estimate that the plan could cost $180 million, which includes citywide curbside recycling. Proponents say the plant would operate cleanly and safely and reduce the city utility’s reliance on electricity purchased from coal-fired plants. They say it also would save millions of dollars each year on landfill fees and reduce the trail of pollution left by trucks commuting to dumps.
But environmental groups contend that the Japanese technology being considered by the city has not been tested on the volume of garbage that would pass through the Ridge Road site. They worry about the possibility of hazardous emissions, including mercury and lead, and want city officials to spend more time exploring alternatives like composting.
Tien holds U.S. licensing rights to the technology, which is owned by the Kinsei Sangyo Co.
The U.S. Environmental Protection Agency told the Ohio EPA in a letter received Feb. 23 that the proposed plant would qualify as a tightly regulated major source of pollution, a designation the city had sought avoid. The federal agency also classified the plant as an incinerator, a word Cleveland officials had contended was inaccurate and refused to utter.”
— Thomas Ott, Cleveland Plain Dealer
Read the whole story: http://blog.cleveland.com/metro/2012/03/cleveland_trash-plant_consulta.html
 CLEVELAND — Cleveland Public Power’s proposal to build a garbage incinerator on Ridge Road is premised on the idea of turning garbage into pellets and then burning them as fuel. Although Cleveland Public Power Commissioner Ivan Henderson has never released a financing plan or finalized cost estimates for the project, he has repeatedly said the City will rely on the pellets to fuel the incinerator and that the project will generate additional revenue by selling excess pellets to various companies, including Cleveland Thermal. Financing for the project would be based on the generation of electricity from the incinerator.
But an elementary mathematical calculation shows that the city has nowhere near enough garbage to make this project work, much less enough to sell “extra” pellets to make money. The City of Cleveland only takes in enough trash from its own residents, as well as the residents of Lakewood and Brooklyn, to fuel a machine from one quarter to one third of the size of what they are planning.
When questioned about the volume of trash at public meetings, city officials have repeatedly stated they will produce enough trash to run the incinerator. But this statement doesn’t hold up against the following simple math: Continue reading Basic mathematical errors will doom incinerator project
CLEVELAND — “In attempting to avoid Clean Air Act regulation of its proposed garbage incinerator as a ‘major’ polluter, Cleveland Public Power has said that it plans to build three smokestacks rather than four to ‘reduce emissions.’ However, in the new plan:…
• The city says it will ‘reduce pollution in nearby neighborhoods by an average of more than 50 percent’ by raising the smokestacks another 25 feet. In reality, though, higher stacks will only spread the same amount of pollution to more neighbors in the city, county and region.
Maybe Mayor Frank Jackson and city officials did not hear what hundreds of Clevelanders said in two months in testimony and in writing: We don’t want or need this new source of harmful air pollution, in our backyard or anyone else’s.”
— Sandy Buchanan, letter to the editor, Cleveland Plain Dealer
 Saturday, February 18, 2012: Protest against proposed Cleveland Incinerator, Southwest corner of W 25th Street at Lorain Avenue. Nidia Arguedas, Claudette Wlasuk, M.J. Muser, and Susan Slotter. CLEVELAND — “In my opinion, the Administration’s response shows a reckless disregard for the safety of Cleveland’s citizens. Cleveland’s city government should be in the business of promoting the general welfare, not putting it at risk.
The Administration says that the people who oppose the incinerator are merely people who don’t want this monstrosity in their backyard. An incinerator spewing out mercury, lead or dioxin should not be built in anyone’s backyard! Even a little bit of mercury, lead, or dioxin, is too much and too dangerous. Doesn’t anyone in the Administration have a conscience?
People need to start calling into question the ethics of the leadership in the City of Cleveland’s administration. People must demand moral and ethical leadership from their government officials. Better to be safe than sorry.”
— Pat Tamburro, Cleveland Plain Press
Read the whole story: http://ohiocitizen.org/wp-content/uploads/2012/03/plainpress_Mar2012.pdf
 Cartoon from Frederick County, MD, 2006, during a local debate over the terms “incinerator” and “waste-to-energy” plant CLEVELAND — Over the past year, Mayor Frank Jackson and Cleveland Public Power have repeatedly insisted that their proposed garbage burning facility on Ridge Road is a “gasifier,” not an “incinerator.” They have taken out full page ads in newspapers to make this point, developed elaborate analogies comparing the proposal to a “toaster,” and argued with citizens holding up “No Cleveland Incinerator” signs at public meetings.
The citizens of Cleveland weren’t fooled by this, however, and neither was the U.S. Environmental Protection Agency. Last week, U.S. EPA, the agency in charge of regulating the Clean Air Act, wrote a detailed review of the city’s proposed air pollution permit and confirmed that the project is indeed an incinerator.
This is not just a debate over semantics, because air pollution rules and requirements for incinerators are stricter and more protective of public health than rules for gasifiers.
Claude Lawrence Cornett, a Cleveland area engineer, researched the patents for the Kinsei-Sangyo technology that the city based its permit on http://www.patentmaps.com/assignee/Kinsei_Sangyo_1.html and found that they all have the word “incineration” or “incinerating” in their titles.
Cornett goes on to explain: “Cleveland Public Power, the Cleveland Division of Air Quality, and others, have been scammed by Kinsei Sangyo and their representatives to think that the proposed at the Ridge Road waste treatment plant will use gasifiers and not solid waste incinerators with energy recovery.”
— Sandy Buchanan, Executive Director, Ohio Citizen Action
“I don’t want to breathe whatever chemicals will come from this incinerator and I definitely don’t want my children exposed to it! We need to focus on cleaning up our city instead of turning it into a dump!”
 Mayor Frank Jackson CLEVELAND — Neighbors from Cleveland, Brooklyn, Lakewood and Cleveland Heights hand-delivered the following letter to Cleveland Mayor Frank Jackson before last night’s City Council meeting:
Dear Mayor Jackson,
Over the past two months, hundreds of Clevelanders have devoted thousands of hours of their time to studying the proposed garbage incinerator on Ridge Road. Citizens from across the city and the region came to public hearings to express their opposition to this facility and submitted written comments in opposition to the draft permit.
Last week, U.S. EPA validated the many environmental and permitting flaws which had been raised by the citizens, including the fact that this facility must be regulated as an incinerator (not merely a “gasifier”) and that the levels of emissions of harmful chemicals would qualify it as a “major” source of pollution.
We urge you to:
1) Withdraw the proposed air permit to install for this facility;
2) Cancel this ill-conceived project, which still has no cost estimates or financing mechanisms;
3) Refocus the City’s efforts on developing a strong recycling, composting, and resource recovery program.
It is clear from the six public meetings over the past six weeks that Clevelanders are eager for alternatives to this incinerator and stand ready to work with your administration to implement them.
— Sandy Buchanan, Executive Director, Ohio Citizen Action
CLEVELAND — Cleveland Utillities Department Director Barry Withers sent a letter on February 23 to Peter Tien of Princeton Environmental Group, telling him they will cancel his contract to design the proposed garbage incinerator unless he corrects deficiencies in his “Design Memorandum” within ten days of the letter. CPP Commissioner Ivan Henderson admitted at a public meeting on February 15 that Tien had submitted new costs estimates for the facility that day, but CPP has yet to make that document public.
Tien has a $1.5 million no-bid contract with CPP to design the proposed garbage incinerator, using the Japanese Kinsei-Sangyo technology that he represents in the U.S. In 2011, Tien was the key figure in the city’s embarrassing proposed no-bid contract with Sunpo-Optu technology to provide LED lightbulbs — a deal that was eventually abandoned by the city. Nonetheless, CPP continued to work with Tien on the highly controversial garbage incinerator proposal.
Despite a contract obligation to hire Clevelanders to work on the incinerator project, Tien allocated 98.5% of his contracting budget to contractors from outside the city, and did not have the money to pay them. One of Tien’s contractors, GT Environmental of Columbus, which drafted the air permit, now appears to be representing Cleveland Public Power, according to a letter Henderson sent to the Cleveland Division of Air Quality on February 23.
— Sandy Buchanan, Executive Director, Ohio Citizen Action
 CLEVELAND — In an attempt to avoid federal regulation as a “major” source of pollution under the Clean Air Act, Cleveland Public Power announced on February 23, 2012, that it plans to have three combustion units at is proposed garbage incinerator rather than four. Cleveland Public Power says it now plans to run the three incinerator units at 96% capacity rather than four units at 72% capacity, as outlined in its draft permit.
The City’s press release stated the following:
“These enhancements will significantly reduce the maximum annual emissions from the CREG [Cleveland Recycling and Energy] Center by an average of more than 25% and also reduce the predicted maximum air quality impact in the nearby neighborhoods by an average of more than 50%.“
However, a chart attached to the same press release shows the following :
- The amount of pollution from soot, which includes fine particles that get into people’s lungs and bloodstream and aggravate asthma and heart disease, is virtually the same in the two proposals, at 78 tons per year
- Emissions of volatile organic chemicals would also remain virtually the same, at an increase of .1%
- “Hazardous air pollutants,” which includes dioxin, lead, mercury, sulfuric acid, cadmium, and hydrogen fluoride, would decrease by only 6.3%
- Dioxin emissions would go up by 38%
- The facility would still be the largest polluter of mercury in the county, at 144 pounds, and lead emissions would be 392 pounds
- Nitrogen oxide emissions would come in just 6% under the federal threshold for major sources of 100 tons per year. CPP claims these emissions would now be at 94 tons, rather than 194 tons. This claim should raise alarms at the regulatory agencies, since permits which contain numbers obviously designed for the purpose of avoiding regulation are known as “sham permits.”
The city’s claim of reducing pollution in nearby neighborhoods by “an average of more than 50%” is a reference to their plan to raise the smokestacks from 175 feet to 200 feet. Of course, this does nothing to reduce the amount of pollution coming from the incinerator and only serves to spread it to more parts of the city, county, and region.
Maybe Mayor Frank Jackson and city officials did not hear what hundreds of Clevelanders were saying over the past two months in their testimony at six public meetings, and their written comments submitted on the draft permit: we don’t want or need this new source of air pollution, in our backyard or anyone else’s.
— Sandy Buchanan, Executive Director, Ohio Citizen Action
 SHAKER HTS — “Earl M. Leiken, the Mayor of Shaker Heights, filed official public comments yesterday on the City of Cleveland’s proposal to build a new garbage incinerator. The mayor’s comments conclude:
“The permit application lists the allowable emissions that would come from the plant, among them pollutants with obnoxious odors associated with them, especially the Dioxin. Such odors can negatively impact communities even when the actual pollutants emitted are within the legally acceptable ranges.
It appears there many unanswered concerns about the amount, type and quality of the trash that will provide the fuel for the plant and the impact of adding such a large new source of air pollution as our area struggles to regain its economic footing.
Finally, I want to impress upon the Division of Air Quality, whose jurisdiction covers all of Cuyahoga County, that such a large new source of pollutants must be evaluated not only for its impact in the immediate neighborhood surrounding the plant, but also the impact in other communities in the County that will also likely be affected.”
— Earl M Leiken, Mayor of Shaker Heights
Read the full text of letter
 CHICAGO, IL — “Unless OEPA can demonstrate this conclusion is in error, we would consider issuance of a synthetic minor permit to be inappropriate and in violation of federal PSD [Major Source Prevent Significant Deterioration] requirements. We would expect the need for OEPA to go back and issue a PSD permit for this proposed facility and that PSD applicability would need to be re-evaluated for the other pollutants to determine if they are at major source levels considering their significance level thresholds. The permit must be re-evaluated to determine whether it was major for non-attainment New Source Review for the PM 2.5 [fine particulate matter (soot) less than 2.5 micrometers in diameter] emissions.
“As noted, the fundamental question of PSD applicability is critical, and could likely result in an entirely new permit process, requirements and record, which will undergo its own EPA review. We do, however, have other comments on this draft synthetic minor permit, which we’ve provided in Appendix A. As you are aware, many people have raised environmental justice concerns and our review considered those issues as well. We have provided several recommendations to further strengthen the permit given the concerns of the community.”
— Genevieve Damico, Chief, Air Permits Section, U.S. EPA Region 5, letter to Michael Hopkins, Assistant Chief, Permitting, Ohio EPA Division of Air Pollution Control, February 23, 2012
CLEVELAND — “To read the maps [78 MB pdf download] is actually easy, but it’s more important to understand how to interpret what they mean to the average neighbor. Each color is a different average daily concentration that will be experienced over the five years they modeled. As you get further away, the concentration gets lower. Purple and dark blue are highest, light pink is lowest. They only modeled the impact to a distance of 2,000 meters, 6,561 feet, or about 1.2 miles away from the stacks. (Not really “well over a mile” as the report says.)
The report states the following:
“The AERMOD [American Meteorological Society/Environmental Protection Agency Regulatory Model] dispersion modeling was performed with the maximum worst case hourly emissions requested in the air permit application. The air quality modeling assumed that all four proposed gasifier lines were simultaneously operating at the maximum operating rate and maximum emission rate for each air pollutant for each hour of the five‐year period.”
Put another way, the maps show the average additional pollution that these neighborhoods will experience every day for five years if the plant runs at max capacity and all things go as planned.
First, some background. They are using the National Ambient Air Quality Standards. These standards are not for a single source. They are what is allowed for the outdoor air. In other words, if the air currently has 50 percent of that pollutant, a new pollution source adds to it. In order to determine impact of a single source such as the incinerator, one needs to know the average and max concentrations already present. So don’t be fooled when someone quotes that the plant will only emit a low percentage of the National Ambient Air Quality Standards. They are allowing that plant to add to our air. That puts a burden not only on health, but on the entire region, because the region must stay below the standards. According to the U.S. EPA –
“The Clean Air Act, which was last amended in 1990, requires [the U.S.] EPA to set National Ambient Air Quality Standards for pollutants considered harmful to public health and the environment. The Clean Air Act identifies two types of national ambient air quality standards. Primary standards provide public health protection, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.”
The U.S. EPA has set National Ambient Air Quality Standards for six principal pollutants, which are called “criteria” pollutants. For example, from the modeling maps, let’s take a look at one of the pollutants, SO2, the rotten egg smell, a known toxin, and is a primary cause of acid rain (mix SO2 with water, get sulfuric acid). It may be important to note the model reports SO2 in concentrations of micrograms per cubic meter of air. The standard uses parts-per-billion or parts-per-million for SO2.
According to the model, the average per hour emission of SO2 for five years can be anywhere from 10% of the max allowable up to more than 40. The maps do not provide the complete upper range of the concentration for any area, only a color area showing the range of that average. In other words, any one of these spots may experience the max predicted concentration at any given time (unpredictable). For SO2, that max is predicted to be 23% of the allowable. So there is a very close neighborhood shown in purple/dark blue that will always experience a range of greater than 20% of the allowable for SO2. The next area, blue, will experience, always, a range of 30-40% of the max allowable; then light blue, a 20-30%; the pinks are less than 20%.
So when they say the plant won’t emit odors, ask them how sensitive they are to that rotten egg smell. We often get it from other plants around town, depending on their operations. It is always unwanted.
For lead, the max range is greater than 13% of the allowable. This is in addition to the exposure currently experienced by an already poisoned and at risk population. Lead poisoning in children has long been a problem in Cleveland, with huge efforts by the public health sector to reduce the incidence. Lead poisoning is thought by some to be one of our region’s worst public health tragedies, annually impacting tens of thousands of our children over several decades if not nearly a century of exposure.
More quotes from the U.S. EPA, not the Ohio EPA, which is a bit different, both in operations, quality, experience, and legality –
“Sulfur dioxide (SO2) is one of a group of highly reactive gasses known as ‘oxides of sulfur.’ The largest sources of SO2 emissions are from fossil fuel combustion at power plants (73%) and other industrial facilities (20%). Smaller sources of SO2 emissions include industrial processes such as extracting metal from ore, and the burning of high sulfur containing fuels by locomotives, large ships, and non-road equipment. SO2 is linked with a number of adverse effects on the respiratory system.
“EPA first set standards for SO2 in 1971. EPA set a 24-hour primary standard at 140 parts-per-billion and an annual average standard at 30 parts-per-billion (to protect health). EPA also set a 3-hour average secondary standard at 500 parts-per-billion (to protect the public welfare). In the last review, EPA also considered, but did not set, a 5-minute NAAQS to protect asthmatics at elevated ventilation rates from bronchoconstriction and respiratory symptoms associated with 5-10 minute peaks of SO2. [This means that high but short concentrations that produce acute, dangerous reactions is a small sector of the population are not considered].
“Current scientific evidence links short-term exposures to SO2, ranging from 5 minutes to 24 hours, with an array of adverse respiratory effects including bronchoconstriction and increased asthma symptoms. These effects are particularly important for asthmatics at elevated ventilation rates (e.g., while exercising or playing.)
“Studies also show a connection between short-term exposure and increased visits to emergency departments and hospital admissions for respiratory illnesses, particularly in at-risk populations including children, the elderly, and asthmatics. EPA’s National Ambient Air Quality Standard for SO2 is designed to protect against exposure to the entire group of sulfur oxides (SOx). SO2 is the component of greatest concern and is used as the indicator for the larger group of gaseous sulfur oxides (SOx). Other gaseous sulfur oxides (e.g., SO3) are found in the atmosphere at concentrations much lower than SO2. Emissions that lead to high concentrations of SO2 generally also lead to the formation of other SOx. Control measures that reduce SO2 can generally be expected to reduce people’s exposures to all gaseous SOx. This may have the important co-benefit of reducing the formation of fine sulfate particles, which pose significant public health threats.
“SOx can react with other compounds in the atmosphere to form small particles. These particles penetrate deeply into sensitive parts of the lungs and can cause or worsen respiratory disease, such as emphysema and bronchitis, and can aggravate existing heart disease, leading to increased hospital admissions and premature death. EPA’s NAAQS for particulate matter (PM) are designed to provide protection against these health effects.”
— Scott Armour, Armour Applied Science, LLC, Director, Cleveland Chapter of the Indoor Air Quality Association
CLEVELAND — Next Thursday, February 23, is the deadline for public comments on Ohio EPA’s proposed air pollution permit for an incinerator at the Ridge Road Transfer Station. If you haven’t already, please send your comments to David Hearne, Cleveland Division of Air Quality, Department of Public Health, 75 Erieview Plaza, Suite 200, Cleveland, Ohio 44114 or email them to DHearne@city.cleveland.oh.us. Comments must be sent (postmarked if mailed) by February 23.
Comments are best when written in your own words and from your own experience. They do not need to be any specific length.
- Cuyahoga County does not need a new source of air pollution, particularly for lead, mercury, and soot. This incinerator would be placed in a community that is already suffering from an unfair burden of pollution and other health problems, and no new pollution sources should be added.
- The City appears to have submitted a “sham permit,” meaning they are artificially adjusting their pollution numbers downward to avoid complying with tougher pollution regulations. If this facility were to run at 100%, rather than the 72% listed in the permit, it would trigger stricter air pollution enforcement and regulations.
- The City has no basis to assume that the technology provided by Kinsei-Sangyo is the “best available technology,” and so the permit should be rejected.
- The City has no basis for classifying this facility as a “gasifier” rather than “incinerator,” except for wanting to avoid stricter EPA regulations.
Please join us for a campaign planning meeting this coming Tuesday, February 21, from 6:30 to 8:00 p.m. at the Neighborhood Family Practice community meeting room, 3569 Ridge Rd, Cleveland (at the corner of Ridge and Denison, next to Dave’s Mercado). We will talk about next phases in the campaign, now that the hearings are over, and take some time to write out comments on the permit.
— Nathan Rutz, Cleveland Campaign Organizer, Ohio Citizen Action
 Municipalities that have pledged Zero Waste CLEVELAND — “Mayor Frank Jackson’s ‘Sustainability Cleveland 2019′ program has set a goal of ‘Zero Waste’ for the City of Cleveland. But the city’s plan to reach this goal seems to have gone astray, as the City has decided instead to focus on building a municipal waste incinerator, and recycling ‘up to 25%’ of its waste.”
— Sandy Buchanan, Executive Director, Ohio Citizen Action
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