PEG Basis of Design Report 08-31-2011

8/3/2019 PEG Basis of Design Report 08-31-2011

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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


Residuals Storage

and Load-Out

Baghouses integral to the

operation of storage silos and

pneumatic transfer of materials



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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


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


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


CY 2009

PM (F + C)

(tons)

CEI Eastlake Plant Eastlake Lake 3,121

RRI Energy Avon Lake Power Plant Avon Lake Lorain 824

FirstEnergy Ashtabula Plant Ashtabula Ashtabula 255


Painesville Municipal Electric Plant Painesville Lake 167

Elyria Foundry Elyria Lorain 163

Lorain Tubular Company LLC Lorain Lorain 100

CPP Ridge Road Potential Total PM (F + C) Emissions (TPY) 99

CEI Lake Shore Plant Cleveland Cuyahoga 84

Cleveland Thermal LLC Cleveland Cuyahoga 73

Cargill, Incorporated - Salt Division Akron Summit 62

The Medical Center Company Cleveland Cuyahoga 29


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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.


20/85

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.


21/85

Attachment A

Ohio EPA Solid Waste Rules

PTI Requirements for an Energy Recovery Facility versus a Transfer Station


22/85

22

MSW Incinerator or

Energy Recovery Facility

OAC Rule 3745-27-50

Contents of the Application

Transfer Station

OAC Rule 3745-27-21


Ridge Road Transfer Station

Application for PTI

(B) The following detail 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.


sheet to be numbered sheet 1, shall

contain the following information:

(a) The name of the solid wastetransfer facility.


and boundary of the solid waste

transfer facility, to be shown on a road

map.

(c) The name, address and telephone

number of the applicant for the solid

waste transfer facility.


owner(s) and operator(s) for the solid

waste transfer facility, if different

from the applicant.

(e) The name and address of the

person who prepared the plans.


sheet, numbered sheet 1, contains the

following information:

(a) The name of the solid wastetransfer facility.


and boundary of the facility, is shown

on a 7-1/2 minute USGS topographic

map.

(c) The name, address and telephone

number of the applicant for the solid

waste transfer facility.


owner(s) and operator(s) for the solid

waste transfer facility, if different from

the applicant.

(e) The name and address of the person

who prepared the plans.

(2) Plan drawings, showing the

following items located within the

facility boundary and within five

hundred feet of the 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


(iv) Existing topography showing


state, as defined in rule 3745-1-02 of

the Administrative Code, with a


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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



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


(iii) Existing topography showing


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.


(d) The limits of the regulatoryfloodplain.

(e) National park or recreation areas,

candidate areas for potential inclusion



purchase areas.


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.


(d) The limits of the regulatory

floodplain.

(e) National park or recreation areas,candidate areas for potential inclusion



purchase areas.


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


(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


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


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



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.


25/85

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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



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


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


director specified in rule 3745-27-22

of the Administrative Code.

(1) A description of how the waste

handling area floor will meet the


director specified in rule 3745-27-22

of the Administrative Code.


26/85

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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



Application for PTI

the Administrative Code.(2) Any variance or exemption

requests from the requirements in rule

3745-27-22, 3745-27-23 or


Code

(2) Any variance or exemption

requests from the requirements in rule

3745-27-22, 3745-27-23 or


Code

(2) For informational purposes only, a

discussion of the following:

(a) The equipment to be used in the

operation and maintenance of the

facility, necessary to evaluate the

requested maximum daily waste

receipt. Such information shall

include, at a minimum:(i) Types of vehicles that will be used

to deliver, handle, and remove solid

wastes, including ash.

(ii) Performance capabilities, 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


27/85

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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



Application for PTI

on the site.(ii) Methods of on-site solid waste

handling, including charging and

handling of the ash. All putrescible

solid wastes received at the facility

shall be incinerated within

twenty-four hours, unless an alternate

incineration schedule has been

approved by the director. All

nonputrescible solid waste shall be

incinerated within the timeframe

specified by the permit.

(iii) Traffic patterns on the site.

(iv) Methods of loading all solid 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


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



Application for PTI

(4) The following plans:(a) A contingency plan detailing

emergency equipment, procedures,

notification, and remediation for the

following:

(i) Discovery of unauthorized wastes.

(ii) Fire, explosion, and spills.

(iii) Equipment failure.

(iv) Handling, removal, and disposal

of solid wastes if all or part of the

facility should become unavailable for

any reason.

(b) A contingency plan that provides

for written notification to the single 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


Code. The "final closure plan" shall

contain, at a minimum, the following

information:

(i) Schedule and description of the

steps necessary to close the facility as

detailed in rule 3745-27-53 of the


(ii) Name, address, and telephone

number of the person or office to

contact regarding the facility during

the final closure period.(iii) Financial assurance information

as specified in rule 3745-27-15 of the


(3) For informational purposes only,the contingency plan detailing

emergency procedures, to address the

following:

(a) Discovery of unauthorized wastes.

(b) Fire, explosion, and spills.

(c) Equipment failure.

(d) If all or part of the transfer facility

should become unavailable for any

reason:

(i) The handling, removal and

disposal of solid wastes.

(ii) The written notification of the

solid waste management district 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


(4) Financial assurance information

and the executed final closure financial

assurance instrument as specified in

rule 3745-27-15 of the Administrative

Code.

(5) All applications shall include the

following:

(a) Copies of letters of intent with

(5) All applications shall include the

following:


(5) Application includes the following:


copies of certified mail receipts. These


29/85

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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



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


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:




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.




boundaries which may be affected by

the proposed solid waste transferfacility.

(iv) The local zoning authority having


(v) The park system administrator, if

any part of the facility is located

within or shares the park boundary.

(vi) The conservancy district, if any



boundary.

(vii) The fire department having



located.

(viii) The division of air pollution

control and the division of water

pollution control of Ohio EPA,

including a written request for

information pertaining to 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,


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:




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.




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



boundary.

(vii) The fire department having



located.

(viii) The division of air pollution

control and the

division of water pollution

control of Ohio EPA,

including a written request for

information pertaining

to any regulatory requirements

under Chapter 3704.

or Chapter 6111. of the Revised

Code.(v) The local air pollution

planning authority having


(b) Letters of acknowledgement from

the owners of all parcels of land to be

used for the solid waste transfer


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MSW Incinerator or


OAC Rule 3745-27-50


Transfer Station

OAC Rule 3745-27-21



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,


permit application are true and

accurate.


31/85

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MSW Incinerator or


OAC Rule 3745-27-51

Criteria for Approval

Transfer Station

OAC Rule 3745-27-22


Ridge Road Transfer

Station Permit Application

for PTI(A) The solid waste incinerator or solid

waste energy recovery facility will be

capable of operating in compliance with

Chapters 3704. and 6111. of the Revised

Code; and

(A) The new or modified solid waste

transfer facility will be capable of

operating in compliance with Chapters

3734., 3704., and 6111. of the Revised

Code.

(A) The new or modified solid

waste transfer facility will be

capable of operating in compliance

with Chapters 3734., 3704., and

6111. of the Revised Code.

(B) The solid waste incinerator or solid

waste energy recovery facility will be

capable of being constructed, operated,

and closed in accordance with Chapter

3745-27 of the Administrative Code, and

with the terms and conditions of the

permit; and

(B) The solid waste transfer facility will

be capable of being constructed, operated,

and closed in accordance with Chapter

3745-27 of the Administrative Code, and

with the terms and conditions of the

permit.

(B) The solid waste transfer facility

will be capable of being

constructed, operated, and closed

in accordance with Chapter

3745-27 of the Administrative

Code, and with the terms and

conditions of the permit.

(C) The solid waste incinerator or 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


(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






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Transfer Station

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Ridge Road Transfer


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



established in rule 3745-27-15 of the

Administrative Code, for providing

financial responsibility for the final

closure of the transfer facility in

accordance with rule 3745-27-24 of the




established in rule 3745-27-15

(I) The solid waste incinerator or solid

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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Transfer Station

OAC Rule 3745-27-22


Ridge Road Transfer


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:


department of natural resources as either a

state nature preserve, a state wildlife area,

or a state scenic river.


managed by the Ohio historical society as

a nature preserve.


department of the interior as either anational wildlife refuge or a national

scenic river.


forest service as either a special interest

area or a research natural area in the

Wayne national forest.

(5) Surface waters of the state designated

by Ohio EPA as either a state 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:


department of natural resources as

either a state nature preserve, a

state wildlife area, or a state scenic

river.


managed by the Ohio historical

society as a nature preserve.(3) Areas designated by the United

States department of the interior as

either a

national wildlife refuge or a

national scenic river.

(4) Areas designated by the United

States forest service as either a

special interest area or a 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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OAC Rule 3745-27-51


Transfer Station

OAC Rule 3745-27-22


Ridge Road Transfer


for PTI

operations;(3) Is sloped so as to direct leachate to

collection points and the leachate

management system, and will not allow

ponding of liquids;

(4) Is designed to be capable of

withstanding the forces and weights

encountered during normal facility

operations;

(5) Is accessible to annual visual

inspection for cracks and breaks; and

(6) Is constructed with materials and

methods which enable repairs to be

made; and

collection points within the 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

PEG Basis of Design Report 08-31-2011

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Transcript of PEG Basis of Design Report 08-31-2011