DEQ Questions and answers part 3

by Richard Lamb, Advance Editor

The clock is ticking on the public comment period on the draft air quality permit issued by the Department of Environmental Quality (DEQ) to Wolverine Power. The public has until November 24 to submit comments to the DEQ and will have the chance to give oral comments in Rogers City October 29 and 30 (see page 1A for story). The Cadillac-based utility is making plans for a 600-megawatt power plant to be built in the Calcite quarry just south of Rogers City. DEQ permit section staffers took nearly four hours October 1 to answer questions posed by audience members at Rogers City High School. The Advance presents the third in a series of reports on those questions and answers from the DEQ experts. The questions may be paraphrased for space and clarity. The DEQ staffer who answers is listed in parenthesis.

Question: Have all of the existing plants in Michigan had to study potential effects that mercury would have like Wolverine has in this project?

(Bob Sills, DEQ toxicology specialist) ?When we look at projects that are going to have some mercury emissions, we look at what length do we need to go to insure environmental and public health protection. We look at how much mercury are they going to emit, we look at any information we have on the form of the mercury that is going to be coming out of their process. We look at the local environment to see if there are some nearby lakes and we want to know if there is already some mercury data for fish, to see if it is already a hot spot or not. We have looked at some facilities that are as low as five pounds of mercury emitted in a year and on the other hand we have looked at some facilities throughout the state that are emitting hundreds of pounds per year of mercury. This particular facility (Wolverine) would be at 47 pounds per year of mercury so it would not be among one of the biggest ones but it is not a real small one either. (Wolverine) used a worst-case assumption for the form of the mercury that would be in their emissions just for the sake of argument, and assumed that mercury would be reactive gaseous mercury. We worked with (Wolverine) and our fisheries biologist and looked at the waters that would be most impacted. They are not being used as great recreational fisheries. Some are only four to eight feet deep and will not be great fisheries but we evaluated them as if they would be in the future and that is how we made the decision here. ?For the other power plants that we are looking at now, we are going through a similar process. We are looking at their mercury emissions and their local potential impacts to water bodies, so it is a consistent process that we are going through.?

Question: If the permit were approved as presented, how would the plant, operated by Wolverine under that permit, compare with other plants, capacity-wise, operating in the state of Michigan today with respect to emissions?

(Julie L. Brunner, P.E., DEQ senior environmental engineer, permit section) –?As a new facility, it has state of the art controls. Many of the existing plants are of an older vintage. The degree of controls on those are not the same or similar. For this size of facility you are going to be looking at emissions profiles that are significantly reduced over a comparable facility. I don?t think there is another circulating fluidized bed (C.F.B.) 300 megawatt boiler operating in Michigan but there are a number of pulverized coal boilers operating that combust coal. If you are looking for emissions profiles for those and compare them to what Wolverine is going to be permitted they would look different.?

Question: Why do you consider this technology to be clean coal technology?

(Melissa Byrnes, DEQ environmental engineer, permit section) ??This is the name the company gave for their project. I think where that is coming from is that there are a lot of these coal-fired power plants out there that are a lot older and they don?t have the (emissions) controls that this new boiler will have. This new C.F.B. technology, which inherently reduces (emissions).?

Question: Although there are no regulations on carbon dioxide emissions today, what happens to the Woverine plant if the federal government decides to regulate carbon dioxide emissions in the future?

(Mary Ann Dolehanty, DEQ acting permit section supervisor) ? ?We did not attempt to quantify carbon dioxide emissions in regards to this plant. We did not attempt to put limits in the permit. What the state of Michigan has elected to do is to approach this from a broad-based perspective. Through an executive order by the governor there was established the Michigan Climate Action Council. That council is charged with coming up with recommendations for where our state is going to go in relation to carbon dioxide regulations. What we may be looking at is new laws, regulations or rules that we have to operate under. If that were to happen, (Wolverine) would be subject to that and would have to make any modifications to comply with those rules.?

Question: The DEQ has no controls over the type of fuel used by Wolverine, as long as it meets the emissions standards. If the Presque Isle County Planning Commission did, in fact, approve the burning of petroleum coke and it was just left off the minutes, does this draft permit address all concerns around using petroleum coke as a fuel? (Byrnes) ??Yes. We have looked at all those things (emissions, storage of fuel, fugitive dust, waste) and there are some conditions in the permit for those. We looked at worst-case emissions from the petroleum coke. They have some limits in their permit for criteria pollutants and if they exceed those, they are going to be in violation of their permit. So they are going to be testing the fuels, sampling it and making sure that they are not going to do anything to exceed their emissions.?

Question: Why is the applicant allowed to chose its own source of fuel and are they going to use the cleanest petroleum coke available?

(Byrnes)??We have to look at the state and federal regulations and (determine) if they are going to meet the state and federal regulations with the fuels they are proposing. We don?t have the authority to tell them to pick a certain type of fuel. We have to evaluate it based on the application that they have submitted and make sure that it meets all the state and federal regulations.?

Question: –What processes will be in place to insure this facility will not go over its allowed emissions?

(William J. Rogers Jr. DEQ environmental quality analyst)??The first line of defense would be the various contiguous emissions monitors for opacity, nitrogen oxides, carbon monoxide, sulfur dioxides, and there are one or two others that I might have forgotten. Those (monitors) are called contiguous. They are supposed to be on all the time. If they are not on all the time, and the amount of time is significant, that is a violation, too. The other thing is I would inspect these facilities. That is part of my job. We conduct unannounced inspections on them. We just show up at the door, with a copy of the permit in hand and go through and see whether they are in compliance with it or not. ?For the renewable operating permit, which is the step after this permit, they would also have to certify regularly and have a ranking person in the organization legally certify that they comply or tell us where they haven?t. There can be enforcement consequences for not reporting that correctly, too. ?Certainly one of the most useful things to see if they are in compliance is you. Because when someone sees something that is not right at the plant, I would really appreciate it if they let me know about it and I could investigate it to see if it is a violation or not.?

Question: –What are the securities and backups for a scrubber failure?

(Byrnes)??They cannot operate the boilers if their control equipment is not operating.?

Question: –What is the environmental impact of mercury emissions?

(Sills) ??The environmental impacts of mercury exposure is very low in the air. In fact thousands of times lower than a level that can be estimated to cause any health effects. Accumulation levels in fish are on the order of about .004 parts per million which is roughly about 100 times lower than a level than probably is existing in fish now in this area which is still lower yet than levels that become of concern for the DEQ as a trigger to issue fish consumption advisories. ?So this would be a very small increment to the levels that already exist and are naturally occurring in fish. It is not enough to bump it up over and get to a level of concern and this is looking at the most highly impacted lake, which is Swan Lake about three miles east of the facility.?

Question ? Where and when has a plant like this been built?

(Brunner) ? ?The best similar source to match Wolverine?s process are two CFB plants operating in Florida. They were permitted in 1999 and went online in 2002. The regulatory agency for this facility is the city of Jacksonville who provided me with compliance data since 2002 when they started up. That data is available and on record as public information.

? Question ? What happens to the fabric filters when they are worn out?

(Rogers)??When they are finally worn out they are disposed of in a landfill.?

Question ? Do you at the DEQ consider the full cycle of mining, transportation and emissions?

(Byrne

s) ? ?We are air quality so we review the emissions coming out of this plant. The mining is coming from another state. We don?t have the authority to go beyond what the regulations state.?

Question ? How will the waste disposal affect the ground water and how is it protected? (Byrnes) ? ?In certain circumstances the ash can be resold and in some cases it is (disposed of) landfill. If it is hazardous waste it will be disposed of in a landfill that can accommodate that.?

Question ? Is public comment considered only from people in this area or do you consider comments from people outside the area?

(Byrnes) ? ?We consider all comments.?