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[Page 1]
PUBLIC
RESPONSE TO
Connecticut Department of Energy & Environmental Protection
Connecticut Materials Management Infrastructure
Request for Information
Relative to materials management infrastructure- including disposal infrastructure,
recycling infrastructure, and composting infrastructure- to meet the goals of the 2023
Draft Comprehensive Materials Management Strategy Amendment to improve
diversion of municipal solid waste for recycling and regaining self-sufficiency in
managing municipal solid waste disposal within Connecticut’s borders.
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THE PROBLEM
Connecticut is facing major problems with inadequate statewide
processing capacity to take care of its municipal solid waste. The existing systems
handling municipal solid waste in Connecticut are waste projects which utilize
“Mass Burn” systems. All of them were developed in response to an archaic
system of handling garbage in Connecticut which relied on inefficient burning of
garbage and use of landfills. These projects, developed between 1985 and 1990,
are now old and highly polluting. They do not meet the lower emissions of state-
of-the art modern technologies.
The existing plants were all developed utilizing special laws which provided
for creation of Resource Recovery Authorities in conjunction with municipalities.
The “Authorities” were able to develop Resource Recovery Facilities which were
designed to receive unprocessed Municipal Solid Waste (MSW), perform some
recycling and burn the remainder to create electricity. The ash created by the
burning of the MSW was then placed in landfill systems.
The statute creating the Resource Recovery Authorities allowed these
entities to issue bonds used for the financing of the development of the projects.
The statute also allowed these facilities to enter into long-term electricity contracts
with Connecticut utility companies at preferred rates. The electricity revenue
contracts enabled the Resource Recovery Authorities to pay off the bonded debt
and were usually tied to the term of the bonds issued by the Authority. At the time
the initial laws were enacted this solution was a major improvement over previous
methods of handling Connecticut’s garbage.
Some improvements were implemented to improve waste handling mostly
dealing with increasing the amount of recycling at each Resource Recovery
Facility. As concerns about polluting emissions created by the burning of the
MSW increased, there was little or no implementation of technological
methods to take care of these problems. Concerns about the landfilling of ash
from the facilities also made it difficult to be able to permit much needed new
landfills. No solutions were provided for capture and conversion of CO2 emissions.
The decision to close the MIRA facility in Hartford after a number of
attempts to replace the facility failed has resulted in the current situation which has
forced many Connecticut municipalities to transport their MSW out of state to
landfills located in Pennsylvania and Ohio.
The most current Connecticut waste-to-energy information (2021) provides
a snapshot of how MSW was handled prior to the closing of the MIRA facility in
SMART Technology Systems, LLC “Public Response” to Connecficut DEEP CMMS Request for
Informafion with confidenfial material redacted.
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Hartford in 2022. The annual MSW capacity was almost 2,200,000 tons at the five
resource recovery plants. Actual MSW in the 2021 time period was just under
1,900,000 tons. With the closing of the MIRA plant in Hartford, more than 700,000
tons of MSW capacity was terminated.
Data provided from U.S. Energy Information Administration and U.S.
Environmental Protection Agency
Connecticut’s Waste to Energy Projects (2021)
While the four remaining resource recovery projects continue operations,
only a portion of MIRA’s waste processing was taken over by these plants. The
balance - in excess of 500,000 tons per year is now being shipped to landfills in
Pennsylvania and Ohio. The remaining four Resource Recovery Facilities
located in Bridgeport, Bristol, Lisbon and Preston are operating at maximum
capacity but still using older, polluting technology. These remaining projects are all
in excess of 30 years old. All of them will require substantial expenditures to be
able to meet current environmental standards. All of them are using waste burning
technology which produces substantial CO2, Methane and Nitrogen Oxides.
Connecticut’s Waste to Energy Projects Emissions
SMART Technology Systems, LLC “Public Response” to Connecficut DEEP CMMS Request for
Informafion with confidenfial material redacted.
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THE SMART SOLUTION
There is a solution available to the State of Connecticut which can provide a
positive, environmentally friendly solution to Connecticut’s waste problem. That
solution includes intense recycling coupled with waste diversion and clean,
efficient, low emissions power generation. This approach will greatly improve
Connecticut’s environment and provide new MSW capacity and jobs. Simple to
implement, with minor changes to existing legislation, this alternative approach
can also help stabilize electrical prices for Connecticut consumers and save
ratepayers millions of dollars. That solution is called SMART Technology
Systems.
These are the key methods that the SMART SOLUTION uses:
- Implementation of “world class” modern recycling methods.
- Recycling of 99% of metals, 98% of glass and preparation of “Refuse
Designed Fuel”.
- Inclusion of anaerobic digestive systems as part of the waste processing
system.
- Utilization of proven “gasification technology” in place of “waste burning
technology”.
- Production of Class 1 Baseload electricity using “synthesis gas” and steam
cycle as well as “biogas” and fuel cell technologies for energy conversion.
- Use of carbon capture technology to reduce air emissions including CO2 plus
conversion into “food grade” CO2.
- Beneficial reuse of cleaner ash residues for use in cement and other products.
- Increase landfill diversion rates to reduce landfill use as much as possible.
- Tipping fee stabilization.
THE SMART SOLUTION WILL IMPLEMENT & ACHIEVE THE
FOLLOWING GOALS:
- Connecticut has established a comprehensive material management strategy
and solid waste plan which includes aggressive recycling goals. SMART’s
project helps Connecticut meet its recycling goals. SMART’s technology
package can help Connecticut increase recycling and lower emissions.
- SMART Waste Processing System uses proven “gasification technology” in
place of “burn technology” to convert refuse derived fuel to a cleaner
synthesis gas/ lower greenhouse gas which should qualify as a Class I
energy source.
SMART Technology Systems, LLC “Public Response” to Connecficut DEEP CMMS Request for
Informafion with confidenfial material redacted.
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- The SMART technology converts/recycles plastics to a clean renewable gas
while meeting emissions goals.
- SMART technology will reduce a significant amount of CO2 while diverting
million tons of waste from landfills and produce clean, base load electricity
on a 24 x 7 basis.
- SMART uses technology with proven track records and best-in-class
emission performance. Our projects will provide high capacity, high
recycling rate, and a high landfill diversion rate, all within a small footprint
while holding costs down for Connecticut residents. This approach will
modernize MSW processing capacity and production of renewable energy
with a high-capacity factor (>90%).
- The SMART approach also provides a carbon dioxide capture and
conversion system to achieve maximum emissions reduction.
- Using minor modifications to existing statutes SMART’s approach can help
stabilize tipping fees in Connecticut.
- The SMART systems are based upon extremely adaptive technologies that
will facilitate the integration of next-generation upgrades as they become
available.
- The SMART solution will confirm Connecticut’s position as a national
leader in addressing the MSW challenge.
SUGGESTED REQUIRED DEVELOPMENT CRITERIA ELEMENTS
Based on our review of Connecticut’s laws and policies we have evolved a
list of development criteria to be applied to any waste processing projects:
1) PROJECT LOCATION- All proposed projects should be located away
from major urban and residential areas. Those projects proposed to be
located in environmental justice communities should be physically
located so as to have little or no impact on those communities.
2) PROJECT SIZE AND TYPE: Proposed projects should be sized to
achieve maximum environmental and recycling benefits. It is suggested
that wherever possible municipal solid waste processing systems be
developed in locations with anaerobic processing systems in proximity to
minimize transportation of waste. Recycling technology on these
properties should be designed to facilitate separation of anaerobic waste
packages from MSW for onsite processing for organic wastes.
SMART Technology Systems, LLC “Public Response” to Connecficut DEEP CMMS Request for
Informafion with confidenfial material redacted.
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3) TRANSPORTATION SYSTEMS: It is imperative that proposed
projects be located in proximity to existing railroad and highway systems
for delivery of waste and also for shipping of materials to be recycled.
4) EMISSION REDUCTION SYSTEMS: Emission reduction and
conversion needs to be an integral part of all future waste processing
systems to achieve important environmental goals, including carbon
dioxide reduction.
5) PROVEN GASIFICATION SYSTEMS: Clean gasification systems
which convert refuse derived fuel into a cleaner synthesis gas with lower
greenhouse gas impacts should qualify as a Class I Renewable Energy
source as anaerobic digestion biogas does under current CMMS
standards.
6) TOTAL INTEGRATED PACKAGE: The total integrated recycling and
renewable energy conversion facility should qualify as a low emissions
advanced renewable energy conversion facility as defied in the
Connecticut Renewable Energy Portfolio Standard.
7) PROJECT DEVELOPMENT PLAN: It is suggested that the State of
Connecticut evolve its Comprehensive Materials Management
Strategy (CMMS) for development and implementation of new waste
processing projects and evolve a cost-effective funding mechanism for
these projects. The funding mechanism should include additional long-
term financing for implementation of new technical improvements to be
implemented at these projects as they evolve. As existing waste to energy
facilities need to be replaced, the CMMS will be able to provide new
projects. These will become permanent waste processing projects to meet
Connecticut’s needs going forward and achieve the waste processing and
environmental benefits in a cost-effective manner.
SMART Technology Systems, LLC “Public Response” to Connecficut DEEP CMMS Request for
Informafion with confidenfial material redacted.