April 8, 2012
Genevieve Damico
USEPA REGION 5
77 West Jackson Boulevard
Mail Code: AR-18J
Chicago, IL 60604-3507
Sent via email to: <damico.genevieve@epa.gov>
Dear Ms. Damico,
We are writing to request that the US Environmental Protection Agency, Region
5, work with the Ohio Environmental Protection Agency to deny the permit to
install for the proposed Ridge Road Municipal Solid Waste energy recovery
facility in the city of Cleveland, Facility ID No. 1318008750, Permit number
P0107767.
On March 23, 2012, the city of Cleveland fired the Municipal Solid Waste energy
recovery facility project consultant, Princeton Environmental Group, for cause.
On February 23, 2012 Barry A. Withers, the Director of Public Utilities for the city
of Cleveland, wrote to Peter Tien, Owner of Princeton Environmental Group
citing the contract between Princeton Environmental and the city of Cleveland for
initial design and environmental permitting of a Municipal Solid waste-to-energy
facility. (attached)
The February 23 letter noted that work submitted by Princeton Environmental did
“…not meet the requirements contained in the Agreement, and that contains
unacceptable errors and faulty research.” The city goes on to say that the work
submitted displayed an unacceptable and unprofessional lack of required care
and skill. The work submitted contained errors of calculation and base values for
projected revenues, waste volume, waste collection amounts, operation days,
and so on. Princeton Environmental was notified that the Agreement was
considered in default of obligations, and they were given 10 days to correct the
deficiencies.
Mr. Tien did submit an updated revised work product on March 10, 2012. The city
reviewed and also found this unacceptable citing “unsubstantiated and
unexplained estimated projections” in a March 22, 2012 letter. The city called out
faulty financial projections, discrepancies in megawatt projections, and questions
on feedstock and fuel pellets. (attached)
Director Withers again states that the work product submitted by Princeton
Environmental continues to demonstrate an absence of required professional
skill and care, and says the city has lost confidence in Princeton’s abilities.
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April 8, 2012
Director Withers’ letter closes saying the contract with Princeton Environmental is
cancelled.
Cleveland Public Power hired Princeton Environmental and Peter Tien, and Mr.
Tien provided engineering input into the PTI based exclusively on Kinsei Sangyo
batch gasifiers. We are concerned that the same lack of required professional
care and skill, as noted by the city of Cleveland, is contained in the permit
application and therefore, the draft permit we reviewed.
As noted in your February 23 letter to Ohio EPA there are serious questions
raised for the draft permit regarding emission calculations and limits, modeling
methodology for various pollutants, compliance, concerns for local ambient air
quality, visibility, soils and vegetation. Concerns for public health were also
raised. Questions for lead and mercury pollution (major areas of public concern
for residents), our region’s non attainment status for particulate matter, and, most
importantly, the city’s lack of communication with the public on key components
of this major new source of air pollution in our neighborhood were noted. We are
grateful for your-in depth careful review of the draft permit. Your February 23
letter brought to light and verified some of the public’s fears as well as raising
additional significant concerns.
Unfortunately your important comment letter as well as the city’s initial letter
announcing the deficiencies in Princeton Environmental’s project deliverables are
dated February 23, 2012, the exact date for the end of public comment. Thus, the
public did not learn about this critical information until it was too late.
We, like the city of Cleveland, noted numerous discrepancies as we examined
the draft permit and other project information. Like the city of Cleveland, we have
lost confidence in Princeton Environmental’s abilities. We question whether
Princeton Environmental provided the diligence, calculations, research and
required care and skills necessary to submit an acceptable permit that will protect
public health. Therefore, we ask that you do everything in your power to deny this
permit.
On the day the comment period ended, Cleveland Public Power submitted
proposed changes to the permit based on new calculations from Princeton
Environmental Group and its consultants. We believe that these changes were
another thinly veiled attempt to avoid designation as a major source, with the
critically important NOx emissions coming in just a hair under the threshold
amount. If Ohio EPA issues a final permit based on information and calculations
from Princeton Environmental Group and its consultants, we will petition the US
EPA to object to the permit.
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April 8, 2012
We want pollution prevention, expanded recycling, composting and zero waste
programs, green jobs, truly renewable energy, safe technologies, and
environmental justice for those who live close to this proposed facility and the
rest of our impacted community.
We look forward to your response to this letter. Thank you for your consideration.
Sincerely,
Sandy Buchanan, Executive Director
Ohio Citizen Action
614 W. Superior Ave, Suite 1200
Cleveland, OH 44113
216-861-5200
sbuchanan@ohiocitizen.org
Randy Cunningham, Chair
NE Ohio Sierra Club Coal and Energy Committee
3623 West Boulevard
Cleveland, OH 44111
216-245-1073
randino@sbcglobal.net
Stuart Greenberg, Executive Director
Environmental Health Watch
3500 Lorain Ave, Suite 302
Cleveland, OH 44113
216-961-4646
sgreenberg@ehw.org
Teresa Mills, Ohio Children’s Health Organizer
Center for Health Environment and Justice
2319 Park Ridge Court
Grove City, OH 43123
614-871-1353
Tmills@chej.org
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April 8, 2012
Chris Trepal, Executive Director
Earth Day Coalition
3606 Bridge Ave.
Cleveland, OH 44113
216-281-6468
ctrepal@earthdaycoalition.org
Cc:
Cheryl L. Newton, Division Director, Air and Radiation
<newton.cheryl@epa.gov>
Richard Angelbeck, Environmental Scientist, Region 5
<angelbeck.richard@epa.gov>
Lara Lasky, Environmental Justice Program Coordinator, Region 5
<lasky.lara@epa.gov>
Scott J. Nally, Director, Ohio EPA <scott.nally@epa.state.oh.us>
Bob Hodenbosi, Administration, Ohio EPA <bob.hodanbosi@epa.ohio.gov>
Mike Hopkins, Permitting, Ohio EPA <mike.hopkins@epa.ohio.gov>