peg basis of design report 08-31-2011
TRANSCRIPT
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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
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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 comprehensivewaste 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 30th
, 2010.
This document is divided into 2 Tasks, Permitting and Basis of Design and each islisted in accordance to the Scope of Work Time Line as shown below:
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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 applicationsubmitted to Ohio EPA on March 19th, 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:
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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/PM10/PM2.5 NA
Gasifier Lines
No. 1 No. 4
Sorbent Injection
(Lime and/or Activiated Carbon)
as needed
Hg and acid gases NA
BaghousePM/PM10/PM2.5and Metal HAPs
PM/PM10/PM2.5 =
6.22 lb/hr(2)
Selective Catalytic Reduction
(SCR)NOx/NO2
NOx =
15.51 lb/hr
Wet-Flue Gas Desulfurization
(Wet-FGD)
SO2, H2SO4, HCl, HF, other
acid gases and
PM/PM10/PM2.5
SO2 =
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/PM10/PM2.5 NA
Residuals Storage
and Load-Out
Baghouses integral to the
operation of storage silos and
pneumatic transfer of materials
Filterable PM/PM10/PM2.5 NA
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Maximum Annual Emissions
Proposed CPP Facility vs Major Stationary Source Thresholds
Air Pollutant
Maximum
Annual Emissions
from CPP Facility
(TPY)
Cuyahoga CountyNSR Major Source Threshold
(TPY)
Attainment
PSD
Non-Attainment
NNSR
PM2.5 (Particulate Matter less than or equal to 2.5microns in diameter)
99.8
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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 Impactug/m3)
Ohio
Acceptable
Impact(ug/m3)
CPP Project
% ofAcceptable
PM2.5 Annual Average 5.7 15 38%
PM2.5 24-Hr Average 19.8 35 56%
PM10 24-Hr Average 7.6 15 51%
SO2 1-hr Average 44.6 197 23%
SO2 Annual Average 5.8 10 58%
SO2 24-Hr Average 21.2 45.5 47%
NO2 1-Hr Average 79.7 188 42%
NO2 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%
H2SO4 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 lowerthan 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.
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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 Sources7
County
NAAQS Air Contaminants(tons of actual CY 2009 emissions reported by major sources)
VOC NOx SO2
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 PM2.5 SIPInventories for Sources in NE Ohio
9
Source Category
Emissions from Ozone and PM2.5 SIP Inventories (tons)
VOC NOx PM2.5 SO2 Total
Major Industrial 3,853 4,796 862 17,760 27,271
Utility 258 23,905 2,158 91,065 117,386Area 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 Sources0.04% 0.03% 1.57% 0.09% 0.10%
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Table 3
Maximum Potential VOC Emissions from the CPP Facility vs Actual Reported CY 2009
VOC Emissions from Operating Major Industrial and Utility Sources7
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 C uyahoga 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 NOx Emissions from the CPP Facility vs Actual Reported CY 2009NOx Emissions from Operating Major Industrial and Utility Sources
7
Major Industrial/Utility Facility City County
CY 2009
NOx (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 NOx 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
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Table 5Maximum Potential SO2 Emissions from the CPP Facility vs Actual Reported CY 2009
SO2 Emissions from Operating Major Industrial and Utility Sources7
Major Industrial/Utility Facility City CountyCY 2009
SO2 (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
ArcelorMittal Cleveland Inc. Cleveland Cuyahoga 568
Oberlin College Oberlin Lorain 403
CPP Ridge Road Potential SO2 Emissions (TPY) 99
Owens Corning Roofing and Asphalt, LLC Medina Medina 56
Table 6Maximum 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 Sources7
Major Industrial/Utility Facility City County
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
ArcelorMittal Cleveland Inc. Cleveland Cuyahoga 180
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
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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
CountyTotal 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 96Portage County 34
Summit County 654
NE Ohio Total 7,083
CPP Ridge Road Potential Total of AllHAP and Air Toxic Emissions (TPY)
39
CPP Ridge Road Project % of NE Ohio
Sources0.55%
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
(NH3)
(tons)
SulfuricAcid
(H2SO4)
(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
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Table 9Estimated Net Reduction in Annual Greenhouse Gas (CO2e) Emissions
from the Operation of the Proposed CPP Facility
CO2e Netting 2011 - 2030 2031 - 2060
Estimated CO2e Emissions from the CPP Project 210,00 210,000
Estimated CO2e Reductions:
(1) Reduced CO2e from transportation to the landfill 3,665 3,665
(2) Reduced CO2e emissions at landfill 319,312 68,965
(3) Reduced CO2e from coal-fired power generation 267,580 267,580
Total Estimated CO2e Reductions 590,556 340,210
Net Change in Annual CO2e 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). Theevaluation 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) andmobile 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 thephotochemical reactions that occur over time.
1The CY 2009 Emissions Inventory can be obtained at:
http://www.epa.ohio.gov/dapc/aqmp/eiu/data.aspx .
1The 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 (NOx) 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 .
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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 .
1The Ohio air toxic pollutants are identified at:
http://www.epa.ohio.gov/portals/27/regs/3745-114/3745-114-01f.pdf .
1The 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).
1The 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 obtainedat: 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 .
1Total 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 Method202 (the condensable emissions component).
1Test 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 .
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(B) Air Permit Application
Air permit application was executed by City of Cleveland and was submitted to Ohio EPA
on March 11th
, 2011.
Section 2: Receipt of Air Permit
It was confirmed by Ohio EPA in July that EPA is in the process of preparing 1st
draft of
Air Permit for Ridge Road Transfer Station Project. More research is required at this time
on CO2 Emission due to new rulings published by Federal EPA in July, 2011.
Once Ohio EPA completes its draft, it is required to post on EPA website for 30 days tofacilitate public comments.
If all moves well, it is estimated that said air permit can be issued in late September or early
October, 2011.
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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% recyclable3) Organic Waste: 37.9% Converted to fuel
4) Ferrous Metal: 4.1% 100% recyclable
5) Non-Ferrous Metal: 1.7% 100% recyclable6) Glass Waste: 4.1% 100% recyclable7) 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%
S ecial Care 0.1%
Pa er 24.8%
Plastics 18.8%
C & D 5%
Ferrous Metal 4.1%
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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 combinedwith 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 allow us to utilize waste as fuel,
boiler permits, OSHA regulations, 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 amodification 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 andcommercial establishments throughout the City of Cleveland and deposit the MSW at theworking 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
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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 permitissued 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 TransferStation 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 undernegative 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 controlequipment (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 RequirementsAny 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
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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 inamounts that exceed the de minimis emissions thresholds. Examples include the
installation of a supplemental gas-fired boiler or air heaters. Other examples include theinstallation 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 minorsource 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 ofthe 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 theconclusion 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 todifferent environmental rules and guidelines. The Resource Conservation and RecoveryAct (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.
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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/IndirectDischarge 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 IndirectDischarge Permit will be required from the NORSD. The application for this permit mustdemonstrate 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 federalcategorical 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 thefacility 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 theoperation 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 poundthreshold 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 byMarch 1st of each year. This reporting is codified in 40 CFR 355 and 370 and required in
ORC 3750.
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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 beexamined 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 1st
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 notexpected 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 40CFR 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.
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Attachment A
Ohio EPA Solid Waste Rules
PTI Requirements for an Energy Recovery Facility versus a Transfer Station
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
(B) The following detail engineeringplans, specifications, and information
for solid waste incinerator or solid
waste energy recovery facilitiesshall 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 detailengineering 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 detailengineering 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 andidentification 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.
(1) The detail engineering plan cover
sheet to be numbered sheet 1, shall
contain the following information:
(a) The name of the solid wastetransfer facility.
(b) The precise geographic location
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.
(d) The name and address of the
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.
(1) The detail engineering plan cover
sheet, numbered sheet 1, contains the
following information:
(a) The name of the solid wastetransfer facility.
(b) The precise geographic location
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.
(d) The name and address of the
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 facilityboundary, shall contain all
information in paragraphs (B)(2)(a) to
(B)(2)(f) of this rule. Those itemsspecified 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. Allinformation 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 thefacility boundary. A scale of one
inch equals no greater than onehundred feet shall be used.
(a) All plan drawings required by
paragraph (B)(2) of this rule shall
include the following:
(i) The property lines of all landowned 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 thefacility boundary. A scale of one
inch equals one hundred feet is used.(a) All plan drawings required by
paragraph (B)(2) of this rule include
the following:
(i) The property lines of all land owned
or leased for the solid waste transferfacility 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
state, as defined in rule 3745-1-02 of
the Administrative Code, with a
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
include those items specified inparagraph (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
occupied structures.
(iii) Existing topography showing
vegetation and surface waters of the
state, as defined in rule 3745-1-02 of
the Administrative Code, with a
contour interval no greater than fivefeet.
(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 regulatoryfloodplain.
(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.
state, as defined in rule 3745-1-02 ofthe Administrative Code, with a
contour interval no greater than five
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.
(c) All existing domiciles.
(d) The limits of the regulatoryfloodplain.
(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 statescenic 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.
contour interval no greater than fivefeet.
(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.
(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 naturalareas 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.
(3) Plan drawings, showing the
following items located within the
facility and within two hundred fiftyfeet 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 handlingareas 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
3745-27-01 of the Administrative
Code.]
(3) A plan drawing, numbered sheet 3,
shows the location of all existing or
proposed waste handling areas and thelayout 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.
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
specified. An individual plandrawing 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 otheroccupied structures.
(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 feetof 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 andpoints 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.
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25
MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
(5) Detail construction andoperational 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 windsduring 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 themethods 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
3745-27-51 of the Administrative
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 thousandfeet 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
criteria for permit approval by 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
criteria for permit approval by the
director specified in rule 3745-27-22
of the Administrative Code.
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
the Administrative Code.(2) Any variance or exemption
requests from the requirements in rule
3745-27-22, 3745-27-23 or
3745-27-24 of the Administrative
Code
(2) Any variance or exemption
requests from the requirements in rule
3745-27-22, 3745-27-23 or
3745-27-24 of the Administrative
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, wasteprocessing 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 recycledmaterials, 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
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
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 wastebeing 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 controlmeasures 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.
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
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 orjoint 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 shallcomply 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
3745-27-53 of the Administrative
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
Administrative Code.
(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
Administrative Code.
(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 inwhich 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 whichthe 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
Administrative Code.
(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:
(a) Copies of letters of intent with
(5) Application includes the following:
(a) Copies of letters of intent with
copies of certified mail receipts. These
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
copies of certified mail receipts. Theseletters 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 theboard of township trustees.
(ii) The single or joint county solid
waste management district in which
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 bythe 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
part of the facility is located within or
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 thebest 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:
(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
waste management district in which
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 transferfacility.
(iv) The local zoning authority having
jurisdiction, if any.
(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
part of the facility is located within or
shares the conservancy district
boundary.
(vii) The fire department having
responsibility for providing fire
control services where the facility is
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 anyregulatory 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.
(c) A notarized statement that, to the
best of the applicant's knowledge, the
detail engineering plans,
specifications, and information in the
letters of intent describe the intendedestablishment 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:
(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
waste management district in whichthe 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 transfer
facility.
(iv) The local zoning authority havingjurisdiction, if any.
(vi) The conservancy district, if any
part of the facility is located within or
shares the conservancy district
boundary.
(vii) The fire department having
responsibility for providing fire
control services where the facility is
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
jurisdiction, if any.
(b) Letters of acknowledgement from
the owners of all parcels of land to be
used for the solid waste transfer
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-50
Contents of the Application
Transfer Station
OAC Rule 3745-27-21
Contents of the Application
Ridge Road Transfer Station
Application for PTI
permit application are true andaccurate.
facility.(c) A notarized statement that, to the
best of the applicant's knowledge, the
detail engineering plans,
specifications, and information in the
permit application are true and
accurate.
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-51
Criteria for Approval
Transfer Station
OAC Rule 3745-27-22
Criteria for Approval
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 solidwaste energy recovery facility is not
located in a floodway; and
(C) The waste handling areas of the solidwaste transfer facility are not located in a
regulatory floodplain.
(C) The waste handling areas of thesolid waste transfer facility are not
located in a regulatory floodplain.
(D) The solid waste incinerator or solid
waste energy recovery facility is 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 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
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.
(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 oroperated 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 allapplicable orders issued by the director,
the environmental board of review, 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 intoconsideration 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 suchfacilities 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 applicableorders 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 intoconsideration whether substantial
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 solidwaste 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 rulesadopted 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 accordancewith Chapter 3746-13 of the
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.
(F) The person or persons listed as
operator of the facility meet the
(F) The person or persons listed as
operator of the facility meet the
(F) The person or persons listed as
operator of the facility meet the
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-51
Criteria for Approval
Transfer Station
OAC Rule 3745-27-22
Criteria for Approval
Ridge Road Transfer
Station Permit Application
for PTI
requirements of division (L) of section3734.02 of the Revised Code and rules
adopted thereunder; and
requirements of division (L) of section3734.02 of the Revised Code and rules
adopted thereunder.
requirements of division (L) ofsection 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 to3734.43. 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
(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 transfer facility in
accordance with rule 3745-27-24 of the
Administrative Code.
(H) The applicant has executed an
instrument that meets the criteria
established in rule 3745-27-15
(I) The solid waste incinerator or solid
waste energy recovery facility is not
located in any of the following areas, in
existence on the date of receipt of thepermit 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 toinstall 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
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-51
Criteria for Approval
Transfer Station
OAC Rule 3745-27-22
Criteria for Approval
Ridge Road Transfer
Station Permit Application
for PTI
waste energy recovery facility is notlocated 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 Statesdepartment of the interior as either a
national wildlife refuge or a national
scenic river; or
(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; or
(5) Surface waters of the state designatedby 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.
waste transfer facility are not locatedwithin five hundred feet of the following,
which are in existence on the date of
receipt of the permit to install application
by 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.
(2) Areas designated, owned, and
managed by the Ohio historical society as
a nature preserve.
(3) Areas designated by the United States
department of the interior as either anational 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 resourcewater, a coldwater habitat, or an
exceptional warmwater habitat, as
classified in accordance with Chapter
3745-1 of the Administrative Code.
solid waste transfer facility are notlocated 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:
(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.
(2) Areas designated, owned, and
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 researchnatural 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.
(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 inexistence on the date the permit to install
application was received by the Ohio
EPA; and
(K) The waste handling areas of the solid
waste transfer facility are not located
within two hundred fifty feet of a domicile
in existence on the date of receipt of thepermit to install application by Ohio EPA.
(K) The waste handling areas of the
solid waste transfer facility are not
located within two hundred fifty
feet of a domicile in existence onthe date of receipt of the permit to
install application by Ohio EPA.
(L) All waste handling at the solid waste
incinerator or solid waste energy
recovery facility will take place insidebuildings, 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.
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MSW Incinerator or
Energy Recovery Facility
OAC Rule 3745-27-51
Criteria for Approval
Transfer Station
OAC Rule 3745-27-22
Criteria for Approval
Ridge Road Transfer
Station Permit Application
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 leachatemanagement 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 tothe 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 op