EPA works out deal for Cleveland Thermal in Ohio to shut coal- and oil-fired capacity

The U.S. Environmental Protection Agency on Oct. 26 filed with the U.S. District Court for the Northern District of Ohio both a complaint against Cleveland Thermal LLC and a proposed consent decree settling that complaint, with the decree calling for shutdown of existing coal- and oil-fired capacity.

The complaint alleges, among other things, that since at least 1987, Cleveland Thermal, or its predecessors, has owned and operated a steam-generating facility ln Cleveland called the Canal Road Facility, which houses three coal-fired boilers: Boilers 101, 102, and 104.

  • The complaint alleges that Boiler 101 underwent major modifications in August 2006 after an extended shutdown, which resulted in significant net emissions increases of SO2 and NOx in violation of the Clean Air Act.
  • The complaint also alleges that Boiler 104 underwent major modifications in June 2005 after an extended shutdown, which resulted in significant net emissions increases of SO2 and NOx in violation of the Clean Air Act.

The lawsuit alleges that Cleveland Thermal has not complied with any of the Prevention of Significant Deterioration (PSD) or non-attainment New Source Review (NA-NSR) regulations that were triggered by the 2006 modification of Boiler 101 and the 2005 modification of Boiler 104 because, among other things:

  • the modifications of Boilers 101 and 104 were undertaken without obtaining a PSD or NA-NSR permit for the construction and operation of modified Boilers 101 and 104;
  • no evaluation of Best Available Control Technologies (BACT) or Lowest Available Emissions Rate (LAER) was undertaken for Boilers 101 and 104;
  • no pollution controls on Boilers 101 and 104 meeting BACT for SO2 were installed and no pollution controls on Boilers 101 and 104 meeting LAER for NOx were installed; and
  • Boilers 101 and 104 have continued to operate without meeting BACT emission limitations for SO2 and LAER emission limitations for NOx, respectively, without complying with all PSD and NA-NSR requirements, and without having PSD and NA-NSR requirements incorporated into an operating permit as required by the CAA and the Ohio State Implementation Plan promulgated under the Clean Air Act.

Cleveland Thermal does not admit the violations alleged in the complaint and does not admit any liability to the United States arising out of the occurrences alleged in the complaint.

A second facility is also covered by this deal. Since at least 2004, Cleveland Thermal has owned and operated a steam-generating facility located at 1921 Hamilton Avenue, Cleveland, Ohio, 44114 (“Hamilton Avenue Facility”), which houses four fuel oil-fired boilers – Boilers 1, 2, 3, and 5 – and one oil and natural gas-fired boiler, designated as Boiler 6.

New gas boiler to be operating by the end of November

Under this deal, in a move that was already well along, Cleveland Thermal will install and commence operation of a natural gas-fired boiler (“Replacement Natural Gas Boiler”) at the Hamilton Avenue Facility on Nov. 30, 2015, that will be cheaper to operate than any other boiler in the system, thereby giving Cleveland Thermal an incentive to maximize the use of the Replacement Natural Gas Boiler until additional natural-gas fired boilers are installed and operational on or before Jan. 31, 2017.

“Canal Road Facility” means, solely for purposes of this consent decree, Cleveland Thermal’s facility at 2274 Canal Road, Cleveland, Ohio, which houses the three coal-fired boilers designated as Boilers 101, 102, and 104, each with a maximum rated heat input of 228 mmBTU/hr.

“Hamilton Avenue Facility” means, solely for purposes of this consent decree, Cleveland Thermal’s facility at 1921 Hamilton Ave, Cleveland, Ohio, housing four oil-fired boilers designated as Boiler 1 (170 mmBTU/hr), Boiler 2 (170 mmBTU/hr), Boiler 3 (170 mmBTU/hr) and Boiler 5 (220 mmBTU/hr), and one No.-6-oil-fired and natural gas-fired boiler designated as Boiler 6 (220 mmBTU/hr).

In this deal:

  • “New NG Cogen Facility” means a natural gas-fired cogeneration facility that Cleveland Thermal elects to construct in the future that generates electricity and steam solely from natural gas but which can include an alternative, emergency back-up source utilizing fuel oil in the event of an External Natural Gas Supply Outage.
  • “New Natural Gas Boilers” means the natural gas-fired boilers with a total capacity of no less than 364,000 mmBTU/lb of steam that Cleveland Thermal is required to install at the Hamilton Avenue Facility.
  • “Replacement Natural Gas Boiler” means the natural gas-fired boiler that Cleveland Thermal is required to install at the Hamilton Avenue Facility to replace Boiler 102 at the Canal Road Facility (which will be retired).
  • “Selected Oil-Fired Boiler” means the oil-fired Boiler at the Hamilton Avenue Facility that Cleveland Thermal selects to retire. It can be Boiler 1, 2, or 3.

Schedule calls for boiler shutowns over the next couple of years

As for the timing of all this changeover:

  • Commencing no later than thirty Boiler Operating Days from the date of Entry of this decree and continuing until such time as Boilers 101 and 104 are retired, at all times when Boiler 101 and/or Boiler 104 is (are) in operation and using coal as fuel, Cleveland Thermal shall: use best efforts to purchase and use the lowest sulfur coal available from local markets; and only burn coal with a sulfur content that enables Cleveland Thermal to continuously comply with its permitted SO2 emission limit of 1.380 lbs/mmBTU based on the monitoring and recordkeeping requirements in the Title V Permit;
  • Commencing no later than thirty days after the entry of this decree and continuing until all boilers at the Canal Road Facility are retired, Cleveland Thermal shall continuously pperate the multiclone at the Canal Road Facility.
  • Commencing no later than thirty days after the entry of this decree and continuing until Boilers 101 and 104 are retired, Cleveland Thermal shall comply with various emissions controls, emission limitations and compliance demonstration methods.
  • By no later than the earlier of forty five Boiler 102 Operating Days after the entry of this decree, or Feb. 1, 2016, Cleveland Thermal shall permanently cease operating Boiler 102 and then quickly retire it.
  • By no later than the earlier of thirty Boiler 5 Operating Days after the date of entry, or March 30, 2016, Cleveland Thermal shall permanently cease operating Boiler 5, then quickly retire it.
  • By no later than the earlier of thirty Boiler 6 Operating Days after the date of entry, or March 30, 2016, Cleveland Thermal shall permanently cease operating Boiler 6, then retire it.
  • By no later than Jan. 31, 2017, Cleveland Thermal shall permanently cease operating Boilers 101 and 104, which will then be retired.
  • By no later than Nov. 30, 2015, Cleveland Thermal shall install and commence operation of a natural gas-fired boiler at the Hamilton Avenue Facility (“Replacement Natural Gas Boiler”) that already has been properly permitted.
  • Commencing on Jan. 1, 2016, and continuing until Jan. 31, 2017, when only one boiler in the system is in operation, Cleveland Thermal shall operate the Replacement Natural Gas Boiler as its first choice among boilers in the system, except during malfunctions of the Replacement Natural Gas Boiler, required annual maintenance of the Replacement Natural Gas Boiler, or external natural gas supply outages.
  • In addition to the Replacement Natural Gas Boiler, Cleveland Thermal shall install natural gas-fired boilers with a total capacity of no less than 364 mmBTU/hr at the Hamilton Avenue Facility. By no later than May 31, 2016, Cleveland Thermal shall submit to Ohio EPA an application for a federally enforceable Permit-to-Install (PTI) for the new Natural Gas Boilers at the Hamilton Avenue Facility.

Said the company website about these operations: “Cleveland Thermal serves its clients from two plants: one located on Canal Road near the city’s Flats District and its Hamilton Avenue location on the bluffs, just east of Downtown Cleveland. Cleveland Thermal’s pipeline consists of nearly 20 miles of piping that transports energy from either of these facilities to your building. In fact, Cleveland Thermal’s underground piping network serves more than 30 million square feet of property. From both of its facilities, Cleveland Thermal puts out 1.25 billion pounds of steam and 18 million tons-hour of chilled water annually and is expanding to meet growing demand.

“The Canal Road plant has the capacity to generate more than 450,000 pounds per hour of 150 psig steam for distribution. This facility serves as Cleveland Thermal’s main source for providing heating to its customers. The Hamilton Avenue plant serves as Cleveland Thermal’s chilled water plant and has 12,000 tons of cooling capacity. Its district chilled water infrastructure was designed as a ‘closed loop system.’ This means that the water is cooled down to approximately 40° for a continuous supply to the central business district.”

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.