PROBLEMS WITH
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Inadequate
details for engineering review demonstrates lack of due diligence
o Only generic block diagrams of major components and manufacturer’s unsupported claims considered along with regulatory limits
o No control of gases from ash unloading from gasification modules specified
o No air pollution controls specified on air pollution control system byproduct treatment (scrubber water treatment, etc)
o Ductwork, fans, layout and air movers not adequately defined to assure containment
o Emergency pressure relief valves not considered
o Low bid purchasing leaves many dangerous possibilities
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No tests
required prior to installation in
o
Stability of Process Unknown on
o High potential for dangerous emissions from process upsets and puffing
o
No analysis of sulfur, mercury, lead, etc in
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Inadequate
monitoring and reporting
o Method not specified for determining heating value of syngas and associated aerosols, corrected for natural gas usage
o No short duration opacity monitoring and recording to detect puffing, emergency releases
o No testing of emissions except through smokestacks
o Not enough monitoring to determine if pollution control equipment operating properly in between annual emission tests (no baghouse leak detectors, etc.)
o Record keeping only required for 5 years, yet cancer can result decades later
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Modeling
only covers stack emissions
o Fugitive emissions occur at ground level or within turbulent wake of building
o Air pollution, noise and congestion from truck traffic not covered
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Regulatory
Deficiencies
o No short duration opacity limits to address process upsets, puffing, etc
o Only regulates 12 substances, many carcinogens etc. not regulated
o Higher emissions allowed than in permit application and federal regulations
o Need to specify oxygen and temperatures applicable to stack concentration limits
o
Permit does not require submission and approval
of environmentally significant specifications Permit does not require tests to
establish applicability and stability of gasifier on
o Does not regulate potential severe hazards during shakedown and process upsets, etc
o Requirements in permit fixed, need to include flexibility to add new requirements as information becomes available
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Fundamental
Flaws in regulatory process
o Cleveland Division of Air Quality has conflict of interest because reports to mayor along with CPP, and OEPA tied in—need to have permit written by USEPA
o No environmental impact statement required because Clean Air Act excluded from NEPA and no equivalent analysis of reasonable alternatives
o Clean air act limited air regulation to 12 substances and many more toxic and carcinogenic substance emissions associated with gasification
o No budget to develop regulations for MSW gasification and incineration
o OEPA regulation of Air Toxics not protective of public health
o Sham permit: heat input restrictions limiting operating capacity to 72.24% of combined capacity to avoid MACT requirements wastes resources and inadequately monitored
o No public review and hearings after comment period on draft permit complete, and major modifications to permit application and permit terms and conditions possible
For details see: http://www.cornettenv.org/1-18-2012-ComPermitIncin.htm