Sierra Club Lake Erie Group

Tires-to-Energy Plant, Position Paper



Tires-to-Energy Plant proposed for Meadville, PA


John Guth, Regional Air Quality Program Manager
Department of Environmental Protection
230 Chestnut Street
Meadville, PA 16335

Re: Crawford Renewable Energy, No. 20-305A

Dear Mr. Guth:

This letter provides comments of the Lake Erie Group of the Sierra Club's Pennsylvania Chapter and David Sublette, a member of the Sierra Club's Lake Erie Group, on DEP's proposed plan approval for the new Crawford Renewable Energy, LLC tire-derived fuel (TDF) electric power generation plant in Greenwood Township, Crawford County (CRE).

The Lake Erie Group of the Sierra Club’s Pennsylvania Chapter submits these written comments[1] on the draft plan approval No. 20-305A for the Crawford Renewable Energy LLC (CRE) Tire Derived Fuel (TDF) facility in Crawford County, PA.

In prior public testimony at the Conneaut Lake public hearing on July 27, the Lake Erie Group opposed the grant of an air quality permit to the CRE facility.  We did so on the grounds that the CRE facility will emit into the atmosphere particulate matter, toxins, and carcinogens at levels that are high enough to seriously damage the health of those downwind from the plant. Unfortunately, the USEPA’s and PADEP’s air quality standards are too low and do not effectively regulate many dangerous metals, organic compounds, and PAH and ultrafine particulate emissions that the combustion of tire-derived fuel produces.  As a result, if the CRE plant is built, its projected emissions will damage the long-term health of families of Sierra Club members living in its vicinity.   This is particularly true of children who play outdoors and the elderly who are more fragile.   Consequently, the CRE facility should not be granted an air quality permit.

Nonetheless, should the Pennsylvania Department of Environmental Protection move forward with the draft plan approval, there are a number of important facts it needs to recognize regarding the likely emissions from this facility and their subsequent impact on the region’s air quality and public health.  

1) Tire-derived fuel has only been used by a tiny number of power-generating facilities in the U.S.

2)  The chemical composition of tires is much different from and more complex than most other fuels used in power generation such as coal.  Burning tires, even in circulating fluidized bed (CFB)-type furnaces, to produce energy creates higher levels of polycyclic aromatic hydrocarbons (PAHs),  chlorine (and resulting dioxins, and furans), zinc, and ash and particulate matter than does the burning of coal.

3) Scientific studies report that burning shredded tires by themselves in CFB furnaces results in incomplete combustion and thus higher than expected emissions.

4)  The actual emissions experience of the few power generation facilities that have used tire-derived fuel is that they have had difficulty meeting clear air standards and in several cases have been shut down as a result.

5) Pennsylvania’s Northampton Generating is not a good predictor of the emissions of Crawford Renewable Energy (CRE) facility.  While both plants are about the same size and use the same CFB furnace technology, Northampton in 2006 burned 814,000 of solid fuels of which tires were 3,000 tons–less than 1 percent of the total.

In brief, power generators in the U.S. have limited experience and even less success with tire derived fuel.  Because the fuel/furnace technology is unproven and indeed has failed elsewhere, DEP must give greater scrutiny to the projected and actual emissions of the CRE plant than it does to other power-generating facilities using more proven fuel/technology combinations.  This is necessary to safeguard the public’s health.

This means that PADEP must conduct more intensive monitoring of the CRE plant with more continuous monitoring of emissions, more inspections, and greater releases of data to the public than it does with proven power generation technologies and fuels.

1. Tire-Derived Fuel, CFB Combustion, and Emissions

Section D. I. (Source & Site Level) Restrictions and I. 001-002 of the draft plan approval sets maximum mmbtu, pounds per hour, and tpy air emissions.  These projects approximately 1,366 tons of emissions of pollutants into the air from the CRE facility annually.  Scientific studies and actual operations of tire-derived fuel plants show that actual emissions are likely to be much higher.  Atal and Levendis report in “Comparison of the Combustion Behaviour of Pulverized Waste Tyres and Coal,” Fuel (1995) that one of the major non-fuel components of tires–carbon black (between 22% and 31% of a tire)-interferes with the full combustion of the fuel within furnaces resulting in the partial combustion of the tire fuel.[2]

In “Fluidized Bed Combustion of Tyre Derived Fuel,” (Experimental Thermal and Fluid Science, 2003), Scala, Chirone and Salatino point out fluidized bed furnaces burning tires have another combustion problem.  Since tire fuel is more volatile than coal, it burns above the furnace’s bed and at lower temperatures, again resulting in higher emissions of pollutants and “troublesome operation.”[3]

As Atal and Levendis observe, “temperature” is a “critical factor which controls conversion efficiency and pollutant formation such as NOx, polycyclic aromatic hydrocarbons (PAHs) and dioxins/furans.”[4]  Thus the low temperature/partial combustion of tire-derived fuel will yield more emissions of these pollutants.

Ramon Alvarez and his research team found the same fuel combustion problems as Scala, et al.    They also found another source of operational problems with the combustion of tire-derived fuel in fluidized bed furnaces.  One of the major minerals in tires is zinc and it combined with other trace elements and led to “slag formation and bottom ash agglomeration.”  The slag and large bottom ash particles “usually remained at the bottom of the bed while the rest of the ashes were fluidizing, causing frequent operational problems. ...The presence of these big particles, close to the air distribution plate, make difficult the proper bed fluidization and the correct feeding of the fuel into the reactor. ...Despite considerable work reported on this problem, the ash-bed material interaction and bed agglomeration are not yet well-known.”[5]

In summary, CRE’s burning tire-derived fuel in its CFB furnaces will produce higher than projected emissions because the carbon black and zinc in tires interfere with combustion and the  operation of the fluidized bed.  Further, the kinetic nature of the combustion process results in the volatile matter of TDF burning above the bed and therefore burning incompletely.  The consequence is higher levels of emissions.

2. TDF Fuel Size and Emissions

Section D. Source Level and Site Level I. 001-002. .   The size of tire derived fuel also impacts on emissions–the smaller the size of the fuel particles, the more complete the combustion, and the lower the emissions.  As with coal, pulverized tire crumbs burn better and release lower emissions than large chunks of fuel.  The shredded tire chips that CRE will use in its furnaces burn far less cleanly than tire crumbs. Caponer, Tenorio, Levendis, and Carlson point out in “Emissions of Batch Combustion of Waste Tire Chips: The Afterburner Effect,” (Energy Fuels, 2003) that “burning chunks of tires can be problematic because of the copious amounts of particulate matter and PAH that are released.”  Burning “1-3 cm chips “resulted in much higher emissions of PAH and particulate matter” than did coal.  While fine tire particles burn better with lower emissions “tire pulverization is currently both challenging and costly” and “it is economically advantageous to burn tires either as whole units or shredded.”[6]


Summary No. 1-2.

This combination of combustion and operational problems, and resultant high emissions have long plagued tire-to-energy plants.  Most recently, high emissions caused the 2007 permanent shutdown of the Tire Energy Corporation’s tire fueled energy plant in Martinsville, Virginia.  Its failure to meet air quality standards led to a joint agreement between the owner and the Virginia Department of Environmental Quality to close the plant.[7]  


3. Misleading Industry Claims and Misleading Experience with Coal-Tire-Derived Fuel Co-Combustion

Section D. Source Level and Site Level I. 001-002.   The CRE/DEP underestimation of furnace operational efficiency and amount of pollutants emitted appears to be based on the experience of the co-combustion of coal and waste tires in on the one hand and inflated claims for CFB furnaces burning tire-derived fuel on the other. 

Liberty Tire Recycling, a major provider of shredded tires for power production points out: “Approximately 10 million tires per year are consumed as fuel at dedicated tire-to-energy facilities, which are specifically designed to burn TDF to create energy. ...When used as an alternative energy source, TDF generates up to 16,000 BTUs per pound - with lower moisture, sulfur, nitrogen and ash than fossil fuels.”[8]


A number of scientific studies bear out some of these claims–both for solely burning TDF or co-firing it with coal.  This is particularly true of the lower moisture content and lower nitrogen emissions, and modestly lower CO and CO2 emissions.  Because of the significant variance in the sulfur content of types of coal, SO2 emissions varied significantly.  With low sulfur coals, burning tires created greater emission, while the combustion of high sulfur coals, had tire-derived fuel producing lower sulfur emissions.[9]  But, as the following illustrates, the carbon, nitrogen, and sulfur emissions from the combustion of the tire-derived fuel are the emissions that are the least dangerous to the public’s health.  Tire combustion releases many much worse pollutants into the air.



4. Waste Tire Chemical Composition and Resultant Emissions


The chemical composition of waste tires differs significantly from coal as noted above and this has a significant impact on emissions from their combustion. 


a. Zinc

Where coal contains little zinc, waste tires typically contain between 1% and 2% zinc.[10]  In a comparison of power plant emissions using coal and a fuel mix of 95% coal and 5% shredded tire particles, Gieré, Smith, and Blackford found that zinc emissions from the fuel mix were 160 times greater than from coal (grams per hour).  At this rate annual emissions of zinc would equal 21 tons of zinc from the mixed fuel versus 130 kilograms from pure coal.  Gieré, et al note this is the equivalent amount zinc contained by a standard ore carrying railroad car.[11]


There is a significant scientific literature that shows zinc inhaled through airborne particulate matter as a contributor to cardiovascular disease.[12]   Another aspect of zinc emissions from tire-derived fuel combustion is that it is emitted in very fine particulate form (PM 2.5) as zinc sulfate.  It “was found to irritate and damage the respiratory tract of humans and animals....”[13]


The CRE plant, using 100% shredded tires as fuel is going to produce zinc emissions at a factor many times the projected emissions in the draft approval plan.  Because of their negative health impact, these emissions need to be closely monitored.


b. Other Toxic Metals

The Gieré, Smith, and Blackford study also found dramatic increases in the emissions of toxic metals and metalloids from the combustion of the coal-tire fuel  mix.  These included antimony, cobalt, and copper.  These emissions, they report,  were “consistent with the higher concentrations of these elements in TDF as  compared to the Indiana coal.”  Much more troubling was the finding that the coal-tire fuel mix produced emissions containing the toxic metals beryllium, vanadium, arsenic, nickel, cadmium and lead.   These elements, observe Gieré, Smith, and Blackford:


are either not detectable or depleted in TDF relative to the pure coal, but their normalized emissions are greater than the unity. At present, this discrepancy is not yet understood.  One possible explanation could be that these enhanced releases might be due to chlorination reactions during combustion. ...Based on these results, we conclude that the high Cl [chlorine]  contents of TDF do not only lead to higher emissions of HCl [hydrogen chloride] but might also lead to formation of gaseous chloride species of some metals which, as a consequence, are then emitted at considerably higher rates.[14] 


The consequence, observe Gieré, Smith, and Blackford, of a 95% coal/5% TDF fuel mix is that “hundreds of kilograms of metals and metalloids, some toxic and carcinogenic, would be emitted per year into the atmosphere when the coal + TDF blend is combusted. For example, more than 200 kg As and nearly 180 kg Pb are emitted over the course of a year when 5 wt.% TDF are co-combusted with coal.”[15]


Alvarez and his research team point out in “Soil, Water, and Air Environmental Impact from Tire Rubber/Coal Fluidized-Bed Cocombustion” the regulatory implications of the dramatically different nature of pollutants from a coal/tire mix instead a pure coal fuel.  “Other different combustion variables compared to the ones used for coal combustion should be used to avoid atmospheric contamination by toxic, mutagenic, and carcinogenic pollutants, as well as hot gas cleaning systems and COx capture systems.[16]


Given these findings and that fact that CRE will burn a 100% tire fuel, it is essential that the PADEP closely monitor emissions of these toxins and carcinogens in order to protect the public health.  These means more frequent tracking of these emissions than the planned annual stack test in the draft approval plan (see Emissions Reporting and Emissions Monitoring below). 


c. Chlorine & Dioxins

As Gieré, Smith, and Blackford point out in their study, one of the problems with burning tires for fuel is that they contain a significant amount of chlorine, which is a toxin in its own right.  E. J. Anthony notes in his review of the literature on fluidized bed furnace technology that the chlorine in waste tires “make them problematic to burn in an environmentally satisfactory way,” even in specially designed CFB furnaces such as the one CRE plans to use.[17]


Part of the problem is that chlorine compounds are related to the production of a class of chemical compounds–polychlorinated dibenzo-p-dioxins (PCDDs), dibenzofurans (PCDFs)–dioxins and furans–some of which are the among the most toxic produced by industrial activity.  In “earth pollutant terminology,” Prashant S. Kulkarni, João G. Crespo, and Carlos A.M. Afonso observe, “they are next to the nuclear catastrophes.”[18]


Dioxins and furans are so dangerous as pollutants because they are very stable, long-lived compounds that bio-accumulate and attach to fatty tissues.  These factors allow airborne particles from power plants to quickly move into and up the food chain, along with being inhaled, and accumulate over a lifetime in human body tissues and organs.[19] 


One of the major sources of dioxins and furans is industrial combustion.  Huang and Buekens point out that these compounds “are formed in the low-temperature postcombustion zone of incinerators through some heterogeneous catalytic reactions occurring in the flue gas - fly ash environment. The detailed chemical reactions are however not well understood.”[20]  They are the consequence of “heterogeneous reactions between the products of incomplete combustion.”[21]


Nonetheless, the presence of relative high levels of chlorine in tire-derived fuel (in comparison to coal), and the problems of its combustion in CFB furnaces suggest that much higher levels of dioxins and furans above the projected amounts in the draft approval plan are likely to be produced.  Because of their very toxic, carcinogenic, and mutagenic properties of these compounds, along with their long-lived and bio-accumulative properties, the PADEP must protect the public health by carefully scrutinizing these emissions (see below).


d. Polycyclic Aromatic Hydrocarbons (PAHs)

PAHs are another toxin that the CRE’s burning of tires will release into the air.  In the combustion of wood or coal, PAHs are typically formed by the partial combustion of fuel particles.  PAHs are also formed by the combination of free radicals released by the combustion process.  Fuels also impact on this process.  In the case of waste tires some of the basic chemical compounds that make up much two-thirds of most waste tires consist of styrene-butadiene (SBR) and polybutadiene.  These compounds, Mastral, Callén, and García note, “are a main source of PAH emissions during their combustion.”  And, they are sources of substantial PAH emissions.  “Coal combustion,” they continue, “is relatively clean compared to tire combustion, where 10-100 times higher amounts of individual compounds have been detected in tire combustion.”  In short, the burning shredded tires, even at high temperatures in CFB furnaces of the sort CRE plans to use, produces high levels and high emissions of PAHs.[22]


 PAHs enter the body through  inhalation and skin absorption.  Once inside the body, they ultimately bind to DNA and proteins.  This process may lead to tumor formation in tissues and organs, and it can cause heritable damage to genes.[23] The Center for Disease Control also reports that developmental and reproductive effects can occur from exposure to PAHs. (  Again, because of their very toxic, carcinogenic, and mutagenic properties of PAH pollutants the PADEP must protect the public health by carefully scrutinizing their airborne emissions by the CRE plant and furnaces (see below).


e. Particulate Matter

These are small particles released into the air by the combustion process.  They consist of partially burned particles of the fuel as well as the carbon products that result from combustion (e.g., soot and ash).  And, as noted in above, PM also contains new chemical combinations produced by the combustion process.  are contain the basic chemical components of the fuel as well as.  Gieré, Smith, and  Blackford found that power plant furnaces burning a coal/TDF mix produced considerably more very fine particulate matter than furnaces using only coal.[24]


Larger PM (PM 10)  can cause or worsen respiratory diseases such as asthma,emphysema, and bronchitis and children are especially vulnerable to them.  Veryfine particulate matter (PM 2.5) is the delivery system that brings the airborne pollutants covered above emitted by burning tires to the human body where theycan be absorbed through the skin, inhaled, or ingested.  When inhaled these very fine particles can travel from the lungs to the blood stream to damage the heart, brain, and other organs.  The odds of death from cardiovascular disease increases by 76% for each 10-unit increment of PM2.5 pollution, according to a report in the New England Journal of Medicine.  The consensus of reputable studies attributes more than 60,000 U.S. deaths annually to particulate matter pollution.

Moreover, respiratory ailments mean missed workdays, school absences, and curbing outdoor activities when air quality is bad.[25]           

Again, because of the role particulate matter plays in dispersing very toxic, carcinogenic, and mutagenic pollutants discussed above, the PADEP must protect the public health by carefully scrutinizing their airborne emissions by the CRE plant and furnaces (see below). 

5. PADEP Risk Assessment/Epidemiological Study  

At the July 27 public meeting in Conneaut Lake PADEP representatives informed the audience that the Department’s risk assessment analysis revealed that the CRE plant’s operations would increase cancer rates by 2 incidences for every million people.  The Pennsylvanians living downwind from this plant have a right to know the risks that PADEP projects that they will run because of the plant’s construction and from the airborne pollutants it emits–projected incidences of and deaths from cancer, respiratory disease, and cardiovascular disease.  Consequently, they need to be explicitly stated in the draft approval plan.

Further, as the PADEP’s health risk assessment findings are at such great variance with the findings of medical research, the department needs to track incidences and deaths from cancer, respiratory disease, and cardiovascular disease downwind from the CRE plant.  This is necessary to test the accuracy of PADEP’s risk assessment projections.  In order to fulfill the Department’s mission of protecting the public’s health, it is essential to insure that its health risk assessments are borne out by actual experience.  This procedure–PADEP’s health risk assessment and study of actual occurrences of projected health risks–must be incorporated into the draft plan approval.  This is necessary because of CRE’s burning of tire-derived fuel will release well known toxins, carcinogens and mutagens into the atmosphere which place Pennsylvanians in the vicinity of the plant at risk.

6. PADEP Emissions Reporting and Emissions Monitoring of the CRE Facility

Given the problems with the CFB furnace technology/tire-derived fuel combination, and given the highly toxic, carcinogenic, and mutagenic nature of the pollutants that the CRE plant will emit into the air (discussed above), it is vital that PADEP rigorously and vigilantly monitor the output of the CRE plant and regularly provide to the public its findings.  Therefore the following provisions need to be added to the draft approval plan:

a. Section D. II. Source and Site Level Testing Requirements. #006  - Add the following.

In the first 24 months of operation stack tests shall be conducted quarterly (not annually) and measure emissions for PM, PM10, PM2.5, N0x, S0x, CO, mercury, lead, VOC, ammonia slip, hydrogen chloride, sulfuric acid, and dioxins/furans.

b. Section D. II. Source and Site Level Testing Requirements. #007 - Add the following.

The quarterly stack tests will measure emissions for all the risk assessment compounds in Table 1.

c. Section D. II.  Source and Site Levels Testing Requirements. #011 CEMS - Add the following.

i. 8 CEMS #8 b - Parameter to be reported VOC

ii. 9 CEMS #9 b - Parameter to be reported Zinc

d. Section D. V.  Source and Site Levels Reporting Requirements.  Plan Approval Terms and Conditions -  - Add the following.

i. #023 - In the first 12 months of operations, the DEP shall inspect the CRE plant and both furnaces, and emissions control devices bi-monthly.  In the second 24 months of operations, the DEP shall inspect the CRE plant and both furnaces, and emissions control devices quarterly.

ii. #024 - In the first 48 months of operation, the DEP will provide quarterly reports to public regarding the CRE plant’s and each furnace’s emissions.

(1) These reports will highlight any failure of CRE to meet emission targets in the air quality draft approval.

iii. #025.  - Data from all CEMS will be made available in such a way as to enable the public to view the data these devices generate in monitoring pollutants in real time.



7. Fuel Supply


Section D. I. Source and Site Level Restrictions 004. a. - b.  Local analyses of waste tires available to fuel the plant that meet requirements in a and b suggest that the CRE facility will have difficulty acquiring enough tires to fuel it throughout its lifetime of operation.  An additional section 004.c. needs to be added that requires CRE to submit and DEP to evaluate a new air quality plan should CRE wish to burn other fuels either with (co-combustion), or to replace shredded tires.



8. Use of Emission Reduction Credits


The Facility will be subject to New Source Review (NSR) since it will emit more than 100 tons per year (tpy) of NOx.[26] According to CRE estimates, this is the only pollutant that will be emitted in “significant” quantities, as defined by Pennsylvania air quality regulations, and so it is the only pollutant that will be subject to special permit requirements.[27] These requirements applicable to the proposed CRE facility include: (1) LAER compliance; (2) compliance with emission standards and limitations; (3) offsetting the emissions according to section 127.210; (4) obtaining ERCs according to section 127.210; and (5) an alternative site analysis. CRE has discussed requirements (1), (2), (3) and (5) in section 9 of their permit application. However, with respect to permit requirement (4), CRE only states that “[t]he facility is committed to securing 291 tons of NOx ERCs” and that it will submit an application to use ERCs in sufficient time to be approved in a Plan Approval.[28] That is in accordance with 25 Pa Code 127.208(2), but part (6) of that same regulatory section states that “ERCs may not be transferred to and used in an area with a higher nonattainment classification than the one in which they were generated.” Thus, in order to ensure that there are sufficient ERCs available for CRE to purchase and then get approved in a Plan Approval, it seems prudent that CRE disclose from where the 291 tons of NOx ERCs will come.



9. Compliance with LAER Requirements


With respect to the LAER compliance requirement for the facility’s permit, CRE has done a control technology analysis in Section 5 of its application. The proposed facility will use Foster-Wheeler circulating fluidized bed (CFB) technology in the combustion/incineration of the proposed fuel source, tire-derived fuel (TDF). According to CRE’s application, more than 250 installations worldwide utilize the same Foster-Wheeler technology, including three units permitted to operate on TDF in Japan.[29] CRE has included in its application a list of approved facilities which will use CFB technology.[30] However, none of the facilities from Japan are listed, and none of the remaining facilities included in CRE’s list use even a fraction TDF as a fuel source. CRE does mention a facility which was permitted to combust 80% TDF, however that facility is not listed in the table with the non-TDF facilities, and therefore does not show the emission rates of the pollutants at said facility. CRE mentions that testing information has been reviewed to aid in their analysis of the proposed facility, but no figures are given. In order to completely grasp the impact that the proposed facility will have upon air quality, such information would be highly valuable. As such, the analysis cannot be complete until such figures are released so they may be separately analyzed, preferably by a third party, for accuracy and impact upon the proposed CRE installation.



10. Compliance with PSD Regulations


Because the proposed facility will be a new major stationary source[31] located in an area designated as attainment, it is subject to Prevention of Significant Deterioration (PSD) regulations.[32] These regulations require: (1) a Best Available Control Technology (BACT) analysis; (2) a PSD increment analysis; (3) a NAAQS impact analysis; (4) a nonattainment area impact analysis; (5) an impact on class 1 areas analysis; and (6) an additional impact analysis.[33] CRE performed the BACT analysis and supplied it in the application where it is stated that the top technology was chosen for all criteria pollutants.[34] CRE has also created models or adequately addressed the analyses required in (2)-(6) above, which show that the proposed facility will be in compliance with those PSD regulations. However, the application fails to address the details surrounding solid waste disposal. Only general references are made of the proposed locations for off-site disposal of byproducts resulting from the combustion process. CRE states waste metal will be transported to reclaiming facilities and mentions they have had numerous inquiries about acquiring ash for beneficial re-use, but again no additional information about these disposal options is offered.[35] Further investigation should be made to ensure proper disposal locations are willing and able to accept the byproducts left over from the combustion of approximately 1,000 tons per day of TDF. Planned primary disposal facilities should be disclosed, as well as secondary disposal facilities should primary facilities suddenly become unable to accept combustion waste.



11. Compliance with NSPS Regulations


The proposed facility will be subject to new source performance standards (NSPS) [36]  due to its combustion capabilities and the fact that it will sell all the electricity it produces on the power grid.[37] Along with emissions standards, this section requires that continuous emissions monitoring systems (CEMSs) be installed for a number of pollutants: Opacity, NOx, SO2, CO, O2, particulate matter, Mercury if it’s required, and CO2 as required under the Greenhouse Gas Reporting Rule.[38] CRE says that it will install the required CEMSs, but there is no explanation of what type will be used, who will manufacture the units, or what each unit’s specifications will be, etc. As such the public cannot be confident that emissions will be accurately monitored and reported, and so an explanation of what CEMSs is a necessary part of the application.  In addition, the use of CEMSs means that  the proposed facility will also be subject to other regulations which detail the manner in which such measurements may be taken.[39] While these regulations concern the facility primarily after it has been constructed and is in operation, there are some requirements which must be taken into account during construction in order for the facility to be in compliance with the sampling and testing procedures when the time to take such measurements comes. There are requirements for “adequate sampling ports, safe sampling platforms and adequate utilities for the performance by the Department of tests on the source”[40] which would be much more difficult to create after the facility has been constructed. Thus, it seems prudent that CRE acknowledge the requirements related to any necessary physical structure in its application rather than post plan approval. There are also regulations related to who may conduct the testing of pollutants, if it’s not done by the PADEP, as well as established procedures for conducting pollutant tests and reporting the information. In order for the application to be complete and for the public to have a complete understanding of how the facility will operate, the PADEP will require CRE to identify what type will be used, who will manufacture the units, and what each unit’s specifications will be.



12. Mandatory Greenhouse Gas Reporting Rule


The proposed CRE facility will be required to comply with Mandatory Greenhouse Gas Reporting Rule, since it will emit more than 25,000 metric tpy of CO2.[41] It will be necessary to install a CO2 monitor in order to facilitate accurate reporting, and CRE explains that such a monitor will be installed.[42] However, CRE only says that one will be installed, but does not give any specifics about the manufacturer, specifications, or anything else. In order for the public to be confident that the CO2 will be accurately measured, properly reported, and to make the application complete, more information about the monitor seems necessary.


CRE’s proposed fuel source is shredded tires. The shredding and processing of tires inherently produces dust and potential fugitive emissions.[43] CRE plans to address this concern by utilizing water sprays to suppress dust formation and by using the facility ventilation system to further eliminate potential fugitive emissions.[44]  Although fugitive emissions may be permitted from this operation, CRE should detail how the facility’s ventilation system will remove fugitive emissions, and how any excess water used during dust suppression will be disposed of.



13. Title V Permit Issues


Due to the fact that the proposed facility will emit more than 100 tpy of NOx and CO, it will be considered a ‘major source’ of such pollutants and CRE will be required to obtain a Title V Operating Permit, as mandated by Pennsylvania regulations and the federal Clean Air Act.[45] As acknowledged by CRE, such permits are more demanding than the plan approval that’s required for the facility to operate in Pennsylvania. The plan approval is a transition to a Title V permit, because such approval allows temporary operation of the facility to show compliance with the plan approval.  What is critical to avoid here is some kind of “automatic” Title V permit approval.  DEP and the public must be assured that the system in fact operates as CRE claims it will and the plan approval requires.  Thus, DEP should require CRE to disclose any and all pertinent information to the public and the state, including detailed information about the systems that will be installed in the facility (whether it be for energy creation and distribution, pollutant monitoring, backup and emergency systems, and even record keeping), the actual performance of the facility and control systems, and anything else which may be deemed material or pertinent to the planning, construction, operation and maintenance of the proposed facility.   Without such information, the public cannot be assured that the facility will offer benefits which outweigh the negatives associated with a TDF power plant.



14. Other Regulatory Concerns


In addition to the regulations that CRE claims apply to the proposed facility, there are other regulations which may also apply. Of particular significance is the plan approval reporting requirements, which explain that ”[e]ach source shall submit reports to the Department containing the information the Department may prescribe relative to the operation and maintenance of the source.”[46] While the ultimate decision of what information needs to be submitted is solely the decision of the PADEP, there are some significant items which pertain to facilities such as the one proposed by CRE. Section 135 of Title 25 of the PA Code requires sources such as the facility proposed by CRE to submit yearly reports about the emissions from the source.[47] As well as requiring that annual reports be filed with the Department, the section also details requirements for record keeping of the emissions and details what the reports must include. Since the proposed CRE facility will be a major source of NOx, it will be required to submit such reports. Although the Department has conditionally approved these plan requirements, an explanation of how such emissions will be tested, how records of such tests will be kept, and a statement that CRE will adhere to the Department’s requirements for such reports once the facility is operating seems relative to the operation of the proposed CRE facility and the application seems incomplete without it.


Since the proposed facility will be a public utility as defined in the Pennsylvania regulations[48], it is appropriate that CRE explain how it will comply with the applicable Pennsylvania regulations.[49] There are requirements for how a facility must deal with and report accidents and complaints, how it may distribute electricity to the power grid, that it must contain certain meters and instruments to measure and record the flow of electricity, and a number of other things.[50] Since the entire purpose of the proposed facility is to generate electricity for public consumption, these regulations must be deemed relative to the operation and maintenance of it. As such, an explanation of how CRE shall comply with the regulations is an important aspect of its application and since such information is absent, the application is incomplete.


Although CRE’s facility will be a privately held entity, it will be required to submit financial reports to the Department so that the economic performance of the facility can be monitored.[51] These regulations seem to relate to or are products of antitrust laws, designed so that the public does not become victim to price fixing or gauging. Although these regulations are applicable to the facility only after it has been built and is operating, they are very important to the protection of the public as a whole. As such, it is in CRE’s best interest to inform the public and the state how they will be complied with. This will not only help CRE fully inform the public and the state of the activities which will take place at the facility, but will also help to assure the public that the creation and operation of the proposed facility will be a useful, important service to the community and will be operated with the best interests of the community in mind.


For the Lake Erie Group, Pennsylvania Chapter, Sierra Club


John Paul Rossi

Conservation Chair

2135 Bellefield Drive

Erie, PA 16509



David Sublette

Meadville, PA


Please send written responses to the care of:

Lake Erie Group of Sierra Club's Pennsylvania Chapter
P.O. Box 1556, Erie, PA 16507


cc: F. Tarbell

[1]       To the extent that a written protest under 25 Pa. Code 127.46 is necessary to preserve Sierra club’s rights to appeal the final granting of plan approval, please consider these comments to constitute a written protect by Sierra club as well.

[2]     Ajay Atal and Yiannis A. Levendis, “Comparison of the Combustion Behaviour of Pulverized Waste Tyres and Coal,” Fuel 74:11 (November 1995): 1570-1581; See also V. K. Sharma, M. Mincarini, F. Fortuna, F. Cognini, and G. Cornacchia, “Disposal of Waste Tyres for Energy Recovery and Safe Environment—Review,” Energy Conversion and Management 39:5-6 (March-April 1998): 511-528; Jefferson Caponero and Jorge A. S. Tenório, Yiannis A. Levendis, and Joel B. Carlson, “Emissions of Batch Combustion of Waste Tire Chips: The Afterburner Effect,” Energy Fuels 17:1 (2003): 225–239.

[3]      Fabrizio Scala, Riccardo Chirone, and Piero Salatino, “Fluidized Bed Combustion of Tyre Derived Fuel,”  Experimental Thermal and Fluid Science 27:4 (April 2003): 465-471.  See also Ajay Atal and Yiannis A. Levendis, “Comparison of the Combustion Behaviour of Pulverized Waste Tyres and Coal,” Fuel 74:11 (November 1995): 1570-1581; and  Ramón Alvarez, María S. Callén, Carmen Clemente, María A. Díaz-Bautista, José M. López, Ana M. Mastral, and Ramón Murillo, “Slagging in Fluidized Bed Combustion of Rubber Tire: Inorganic Component Evolution,” Industrial and. Engineering Chemistry Research 43:24 (2004): 7762–7767.

[4]     Atal and Levendis, “Comparison of the Combustion Behaviour of Pulverized Waste Tyres and Coal.”

[5]     Ramón Alvarez, María S. Callén, Carmen Clemente, María A. Díaz-Bautista, José M. López, Ana M. Mastral, and Ramón Murillo, “Slagging in Fluidized Bed Combustion of Rubber Tire: Inorganic Component Evolution,” Industrial and. Engineering Chemistry Research 43:24 (2004): 7762–7767.

[6]     Jefferson Caponero, Jorge A. S. Tenório, Yiannis A. Levendis, and Joel B. Carlson, “Emissions of Batch Combustion of Waste Tire Chips: The Afterburner Effect,” Energy Fuels 17:1 (2003): 225–239.

[7]     Duncan Adams, “Henry County Tire-burning Facility Shuts Down: Tire Energy Corp. Struggled Through Three Years of Operation to Meet Virginia's Air Quality Standards,” Roanoke Times, 25 October 2007; ABI-Inform,

[8]     “Tire Derived Fuel Produces 25 Percent More Energy Than Coal, Reduces Carbon Dioxide Emissions by 19.5 Percent,” PR Newswire, 21 April 2011; ABI-Inform, Document URL:

[9]     Jung Rae Kim, Jung Soo Lee, and Sang Done Kim, “Combustion Characteristics of Shredded Waste Tires in a Fluidized Bed Combustor,” Energy 19:8 (August 1994): 845-854; Yiannis A. Levendis, Ajay Atal, Joel Carlson, Yury Dunayevskiy, and Paul Vouros, “Comparative Study on the Combustion and Emissions of Waste Tire Crumb and Pulverized  Coal,” Environmental Science and Technology 30:9 (1996) 2742–2754; Bonnie Courtemanche and Yiannis A. Levendis, A Laboratory Study on the NO, NO2, SO2, CO and CO2 Emissions from the Combustion of Pulverized Coal, Municipal Waste Plastics and Tires,” Fuel 77:3 (February 1998): 183-196; Reto Gieré, Katherine Smith, and Mark Blackford, “Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station,” Fuel 85:16 (November 2006): 2278-2285; S. Singh, W. Nimmo, B. M. Gibbs, and P. T. Williams, “Waste Tyre Rubber as a Secondary Fuel for Power Plants,” Fuel 88:12 (December 2009): 2473-2480.

[10]     V. K. Sharma, M. Mincarini, F. Fortuna, F. Cognini, and G. Cornacchia, “Disposal of Waste Tyres for Energy Recovery and Safe Environment—Review,” Energy Conversion and Management 39:5-6 (March-April 1998): 511-528; Takeshi Amari, Nickolas J. Themelis, and Iddo K. Wernick, “Resource Recovery from Used Rubber Tires,” Resources Policy 25 (1999): 179-188; Ajay Atal and Yiannis A. Levendis, “Comparison of the Combustion Behaviour of Pulverized Waste Tyres and Coal,” Fuel 74:11 (November 1995): 1570-1581.

[11]     Reto Gieré, Katherine Smith, and Mark Blackford, “Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station,” Fuel 85:16 (November 2006): 2278-2285.

[12]      Urmila P. Kodavanti, Mette C. Schladweiler, Peter S. Gilmour, J. Grace Wallenborn, Bhaskar S. Mandavilli, Allen D. Ledbetter, David C. Christiani, Marschall S. Runge, Edward D. Karoly, Daniel L. Costa, Shyamal Peddada, Richard Jaskot, Judy H. Richards, Ronald Thomas,  Nageswara R. Madamanchi, Abraham Nyska, et al, “The Role of Particulate Matter-Associated Zinc in Cardiac Injury in Rats,” Environmental Health Perspectives 116:1 (January 2008): 13-20;  P. S. Gilmour, A. Nyska, M. C. Schladweiler, J. K. McGee, J. G. Wallenborn, J. H. Richards, U. P. Kodavanti, et al, “Cardiovascular and Blood Coagulative Effects of Pulmonary Zinc Exposure,” Toxicology and Applied Pharmacology 211:1 (February 15, 2006): 41-52.

[13]     Reto Gieré, Mark Blackford, and Katherine Smith, “TEM Study of PM2.5 Emitted from Coal and Tire Combustion in a Thermal Power Station,” Environmental Science and Technology 40:20 (2006):  6235–6240.

[14]     Gieré, Smith, and Blackford, “Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station.”

[15]     Gieré, Smith, and Blackford, “Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station.”

[16]     R. Alvarez, M. S. Callén, C. Clemente, D. Gómez-Limón, J. M. López, A. M. Mastral, and R. Murillo, “Soil, Water, and Air Environmental Impact from Tire Rubber/Coal Fluidized-Bed Cocombustion,” Energy Fuels 18:6 (2004): 1633–1639.

[17]     E. J. Anthony, “Fluidized Bed Combustion of Alternative Solid Fuels; Status, Successes and Problems of the Technology (Review Article),” Progress in Energy and Combustion Science 21:3 (1995):  239-268

[18]     Prashant S. Kulkarni, João G. Crespo, and Carlos A.M. Afonso, “Dioxins Sources and Current Remediation Technologies — A Review” Environment International 34:1 (January 2008): 139-153.

[19]     Kulkarni, Crespo, and Afonso, “Dioxins Sources and Current Remediation Technologies;” Baoning Zhang, Fan Meng, Chune Shi, Fuquan Yang, Deyong Wen, Jonatan Aronsson, Philip K. Gbor, and James J. Sloan, “Modeling the Atmospheric Transport and Deposition of Polychlorinated Dibenzo-p-dioxins and Dibenzofurans in North America,” Atmospheric Environment  43:13 (April 2009): 2204-2212; Franz Schuler, Peter Schmid, and Christian Schlatter, “Transfer of Airborne Polychlorinated Dibenzo-p-dioxins and Dibenzofurans into Dairy Milk,” Journal of Agricultural and Food Chemistry 45:10 (1997): 4162–4167.

[20]     H. Huang and A. Buekens, “On the Mechanisms of Dioxin Formation in Combustion Processes,” Chemosphere 31:9 (November 1995): 4099-4117.

[21]     Kenji Tagashira, Isao Torii, Kazuyuki Myouyou, Kazumitsu Takeda, Takayuki Mizuko, and Yoshitaka Tokushita, “Combustion Characteristics and Dioxin Behavior of Waste Fired CFB,” Chemical Engineering Science, 54:22 (November 1999): 5599-5607.


[22]     A. M. Mastral, M. S. Callén, and T. García, “Fluidized Bed Combustion (FBC) of Fossil and Nonfossil Fuels. A Comparative Study,” Energy Fuels 14:2 (2000): 275–281.  See also A. M. Mastral, M. S. CallÉn, T. Garcia, and J. M. Lopez, “Benzo(a)pyrene, Benzo(a)anthracene, and Dibenzo(a,h)anthracene Emissions from Coal and Waste Tire Energy Generation at Atmospheric Fluidized Bed Combustion (AFBC),” Environmental Science and Technology 35:13 (2001): 2645–2649; Reto Gieré, Katherine Smith, Mark Blackford“Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station,” Fuel 85:16 (November 2006): 2278-2285.

[23]     U.S. Dept. of Labor, Occupational Safety & Health Administration, Chemical sampling information: Benzo(a)pyrene, 2007 (; Yiannis A. Levendis,  Ajay Atal, and Joel B. Carlson, “On the Correlation of CO and PAH Emissions from the Combustion of Pulverized Coal and Waste Tires,” Environmental Science and Technology 32:23 (1998): 3767–3777.

[24]     Gieré, Smith, and Blackford“Chemical Composition of Fuels and Emissions from a Coal + Tire Combustion Experiment in a Power Station;” Zhenlei Wang, Henning Richter, Jack B. Howard, Jude Jordan, Joel Carlson, and Yiannis A. Levendis, “Laboratory Investigation of the Products of the Incomplete Combustion of Waste Plastics and Techniques for Their Minimization,” Industrial and. Engineering Chemistry Research 43:12 (2004): 2873–2886.

[25]     D. W. Dockery, C. A. Pope, X. Xu, J. D. Spengler,. J. H. Ware, M. E. Fay, B. G. Ferris, Jr. F. E. Speizer, “An association between air pollution and mortality in six U.S. cities,” New England. J. Medicine, Dec. 1993; 329:1753-59;  and C. A. Pope, M. J. Thun, M. M. Namboodiri, D. W. Dockery, J. S. Evans, F. E. Speizer, C. W. Health,  “Particulate air pollution as a predictor of mortality in a prospective study of U.S. adults,” Am. J. Respir. Crit. Care Med., 1995, 151:669-74;  See also Dockery, D.W, and Pope, C.A. “Acute Respiratory Effects of Particulate Air Pollution,” Annual Review of Public Health, May 1994, 15:107-32; and EPA/600/R-06/063, July 2006, Provisional Assessment of Recent Studies on Health Effects of Particulate Matter Exposure (ttp://

[26]      “The NSR requirements of this subchapter also apply to a facility located in an attainment area for ozone and within an ozone transport region that emits or has the potential to emit at least 50 TPY of VOC or 100 TPY of NOx.”. 25 Pa Code 127.201(c).

[27]      25Pa Code 127.205.

[28]      Section 9.2.1 of CRE’s application. The 291 tons of NOx ERCs comes from CRE’s projected output of about 252.95 TPY multiplied by the offset ratio of 1.15:1, set in 25 Pa Code 127.210.

[29]      Section 1.1 of CRE application.

[30]      Table 5.1-1.

[31]      40 CFR 52.21(b)(1)(i)Major stationary source means: (b) […] any stationary source which emits, or has the potential to emit, 250 tons per year or more of a regulated NSR pollutant. The proposed facility will emit, according to CRE estimates, approximately 252.95 TPY of NOx and 690 TPY of CO. Section 3 of CRE Application.

[32]      Pennsylvania has adopted the PSD requirements in 40 CFR 52 in their entirety. 25 Pa Code 127.83.

[33]      40 CFR 52.21(j)-(p).

[34]      Section 4.1.1 of CRE application.

[35]      CRE application Section 2.4.4.

[36]      Pennsylvania has adopted the Federal regulations concerning NSPS in 40 CFR 60.

[37]      40 CFR 60.40Da

[38]      Section 4.2.3, p. 9.

[39]      See generally, 25 Pa Code 139.

[40]      25 Pa Code 139.1.

[41]      40 CFR 98.

[42]      Section 4.1.9, p. 7

[43]      CRE application Section 3.2.

[44]      Id.

[45]      25 Pa Code 127.501. Pennsylvania established requirements for a Title V operating permit in response to the EPA promulgating such regulations in 40 CFR 70.

[46]      25 Pa Code 127.12b(c) (emphasis added).

[47]      25 Pa Code 135.

[48]      52 Pa Code 57.1: Definitions. Public utility—Persons or corporations in this Commonwealth owning or operating equipment or facilities for generating, transmitting, distributing or furnishing electricity for the production of light, heat or power to or for the public for compensation. The term does not include either of the following:  (i) A person or corporation not otherwise a public utility who or which furnishes service only to himself or itself.  (ii) A bona fide cooperative association which furnishes service only to its stockholders or members on a nonprofit basis.

[49]      Title 52 Subpart C of the Pennsylvania Code.

[50]      See generally, 52 Pa Code 57.

[51]      See generally, 52 Pa Code 71.