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SB 14 Waste Minimization Plan DTE Stockton, LLC April 2018 2.5 Identification and Evaluation of Source Reduction Measures The primary objective of SB 14 is to develop and screen source reduction measures, considering at a minimum,five approaches.The five approaches and the results of screening source reduction measures against the approaches, at DTE Stockton, is summarized below. 1. Input changes:Biomass is the"input'for DTE Stockton;the woody materials used to fuel the electrical generation plant. The material is comprised of waste wood from sawmills, forest thinning produced in fire prevention,agricultural orchard removals and urban wood waste.The DTE Stockton accepts input locally from agricultural sources and urban wood waste. The input for DTE Stockton was initially coal,but that changed to biomass in 2013. 2. Operational Improvements: Originally a coal-fired cogeneration facility,DTE Stockton was converted to a biomass-fueled facility in 2013. That operational improvement significantly reduced environmental impacts associated with both waste and air quality. The plant now runs on 100% wood-waste biomass fuel derived from nearby urban and agricultural sources. DTE Stockton produces 49 megawatts of clean, renewable energy, enough to power more than 30,000 homes in San Joaquin County. 3. Production Process Changes:The primary function of the DTE Stockton facility is to produce electricity, and the process is consistent with industry standards. The fuel chosen to produce electricity is a variable that was changed in 2013. The facility was converted from a coal-fired cogeneration facility to a biomass-fueled facility. A further production process is highly unlikely in the near future. 4. Product Reformulations: The DTE Stockton facility "product' is electricity. Reformulation options are not technically feasible at this time. S. Administrative Steps: The generation of fly ash and bottom ash is a byproduct of using biomass to generate electricity. Administrative steps to prevent the disposal of this byproduct as a hazardous waste have recently been implemented. The facility is conducting an outreach effort to locate disposal options that will create a beneficial reuse, as opposed to the routine disposal of ash to a hazardous waste landfill. This administrative action will not alter the volume of material being used as fuel in the cogeneration process to make electricity, but it will reduce the volume of material disposed as hazardous waste. 2.6 Multi-Media Effects Implemented source reduction measures are not intended to shift the transfer of waste from one environmental medium (air, land, or water) to another. The Plan includes an evaluation and, to the extent practicable,a quantification of the effects of the chosen alternative on all three environmental media. Air - The DTE Stockton facility converted from the use of coal as a fuel to biomass (wood) in 2013.Different fuels emit different amounts of carbon dioxide(CO2)in relation to the energy they produce when burned. Changing the use of coal as a fuel to biomass has reduced the amount of CO2 released into the atmosphere at the facility. The preferred source reduction method discussed in Section 2.7 does not transfer waste impacts to impacts on air resources. 294354 5