DEQ questions part four

by Richard Lamb, Advance Editor Answers to many questions given by the public were given at an October 1 meeting at the Rogers City High School (RCHS) conducted by the Michigan Department of Environmental Quality. Experts from the Air Quality Division (AQD) patiently answered questions for nearly four hours on the proposed power plant planned by Wolverine Power. The Wolverine Clean Energy Venture is a 600-megawatt coal-fired steam electric power plant to be built in the Calcite quarry just south of Rogers City. DEQ issued a draft permit to construct in September and is currently conducting the public comment period until November 24. In an effort to provide clear information from that meeting, the Advance presents the fourth in a series of reports on most of 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?Did you account for subsistence fishing in your mercury analysis?

(Robert Sills, DEQ toxicology specialist)??Whenever we do an evaluation of something involving mercury and the exposure that can result from deposition and accumulation in fish, the exposure is going to depend on how much fish people eat. For some people, they could be subsistence fishermen. That means that they subsist on the fish. The fish that they catch and eat is a major part of their diet. It is the major protein in their diet. The difference is this. In our approach, we assume that someone is going to eat what roughly equates to one half-pound meal every two weeks of the predatory fish?the ones that accumulate the mercury the most. We assume that they are coming from the lake that is most impacted, even if those fish don?t exist right now. We assume that someone is going there for the long term, catch the fish, and eat their catch (in accord with Environmental Protection Agency (EPA) guidelines)?It is possible some people could eat more than that, but our regulations don?t cover that possibility. If that is actually happening, we can look at that. In this particular case, I don?t think that is a reality. I think that the lakes we have looked at are not great recreational fisheries right now. I doubt that it would be a reality and I don?t want to evaluate something that is not a reality. I want to try to characterize realistic risks for people who might eat fish from these lakes.?

Question?What areas do you evaluate in addition to emissions from the plant directly coming from the stacks?

(James G. Haywood, DEQ senior meteorologist, modeling and meteorology unit)??We also look at the emissions that come from their emergency generator, their fire pumps, we looked at the fugitive dust that comes off the coal piles. We even looked at the dust that is kicked up by the trucks going in and out. So when we looked at the particulate, it is a full comprehensive review. It is not just what is coming out from coal or the combustion of other fuels.?

Question?How often will someone be at the plant to check the monitoring system and how much do you trust self-monitoring?

(William J. Rogers Jr., DEQ environmental quality analyst, Gaylord office)??I am skeptical as it is my job to be skeptical. It is possible to fool us, but they can?t do it forever.? Question?Can you tell if the power plant proposed would create more or less emissions than the sugar factories in the Bay City area, specifically the smell? (Rogers)??I was in charge of enforcement against Monitor Sugar in the office I worked previously. Most of the emissions that we dealt with from them were odor emissions, which would be coming off of the pulp dryer or the ponds when they didn?t circulate the water properly. Bacteria would consume all the sugar in the water and it would go anaerobic, which means black and bubbly and very unpleasant. Odors are a whole different realm than what you are talking about in a coal-fired boiler. They had a coal-fired boiler at that time, too, but it was way smaller than anything here. It was also very old and had a lot of mechanical problems. It is really very difficult to compare the two.?

Question?Explain what kind of auditing is done on an annual basis?

(Rogers)??Each year they would be running a relative accuracy test. It is not enough to put an emissions monitor on a stack and expect that it is going to work. You have to challenge it somehow and make sure that it is accurate enough. There are federal standards on how accurate is accurate enough. Each year they would be running a relative accuracy test on the monitors.?

Question?A representative from the Sierra Club recently told our local planning commission that since our state has not permitted a coal plant since the 1980s, that the DEQ is not competent to protect the public health and safety. Do you believe that you are competent to protect the public health and safety?

(Byrnes)??I think we are very competent. You can tell from our backgrounds alone and the questions that we answered tonight?and a few of them were difficult?that we may not have the information right in front of us but we have looked at all of this information in detail and I think we are very competent to do this.? (Haywood)??Just because we haven?t permitted one, doesn?t mean they are not looked at constantly. They are always being retrofitted and they are always being modified and when they are being modified, they have to go through a permitting process. Just because it is a new power plant, doesn?t mean they are not being reviewed all the time.? (Sills)??If someone did say that we are not competent to do our jobs, I am very hurt. I am very disappointed by that. I find it puzzling that someone would say that about us. I think that any comment like that is not going to be taken professionally and personally very well. Everyone has a right to their opinion and I appreciate all opinions. I hope that through our interactions here tonight, if people came here thinking that, I hope that we can impress upon people that we are competent and we do know what we are doing and we are doing a very good job at it. Certainly there is room for improvement, and as I said earlier, if there are some things that we have overlooked, we will keep on evaluating issues as they come up to make sure we get things right.?

Question?Is burning wood safer to human health than burning petroleum coke?

(Byrnes)??We based it on the worst-case emissions for certain pollutants (and that was) for petroleum coke. We didn?t do a lot of evaluation on the biomass because the emissions factors were a lot less than that from the coal or the petroleum coke.? (Sills)??It is hard for me to say one is safer than another because we evaluated the different fuels and they all pass the test for safety. I can only say that for all the scenarios that they have proposed and that we have evaluated they have passed the safety test under our rules and regulations.?

Question?Can Wolverine assure local citizens that the air and water will be kept clean during the plant?s lifetime?

(Byrnes)??I can answer this on the basis that their air permit will be good for the lifetime of the plant. They will have to renew it, but they will have to comply with all their limits for the lifetime of the plant.? Question?Would the information from the plant stack monitors be sent to the DEQ? (Rogers)??Plant personnel would send us a report of deviations and they would keep the full report on file. If I show up and ask for it, they should have it. It would be better for them if they did.?

Question?Having established that you are qualified to conduct this permit process, and given your extensive review and the conditions established in the draft permit, do those conditions effectively protect the community of Rogers City and the county of Presque Isle? I would like each of you to answer this.

(Byrnes)??Yes.? (Julie Brunner, P.E. DEQ senior environmental engineer, permit section)??Yes.? (Haywood)??Yes.? (Sills)??Yes.? (Rogers)??If they comply with it.?

Question?Has Wolverine provided detailed financial justification for not burning cleaner fuels?

(Byrnes)??Yes they did a fuel analysis and they showed their costs. It was economically feasible for them to burn pet coke. That is why they are using it.? Question?What is the effect of the passage of the state?s recent energy package and renewable portfolio standard on Wolverine Clean Energy Venture? (Mary Ann Dolehanty, acting supervisor, AQD)??We are not looking at that as part of our permit review. That is independent. I know that there are some requirements for renewable portfolio standards?I believe it is 10 percent by 2015. So that would be an independent review done through the Public Service Commission.?

Question?Why isn?t the DEQ requiring Wolverine to use wind energy in this permit?

(Dolehanty)??It is the same with the wind power. They did not propose wind power to us, nor did we review or consider wind power in our analysis. We believe that falls outside of our authority.?

Question?Do the permit conditions assure that the public health is protected when the plant burns any type of permitted fuel, including petroleum coke?

(Byrnes)??Yes it does and there is a limit on the percentage of petroleum coke that they can burn. We look at the worst-case emissions from the fuels that they will be burning.? Question?What are the appeals procedures, should this permit be issued?

(Dolehanty)??The federal rule has a mandate that if an appeal is filed, the permit is stayed. So although it is issued, it is not effective and construction cannot begin until the appeal process has run its course. The difference with our state rules is that we did not add a requirement that the permit would be stayed. So in the event that a permit is issued, the permit becomes effective immediately and construction could commence immediately, unless, for example, an appeal would be file in circuit court and a judge put a stop order or a stay on the permit.?

Question?Will the unloading process and piles of coal be regulated as far as emissions?

(Haywood)??We went back and forth with the applicant (Wolverine) to make sure that they included everything and I think we did a pretty good job. We included everything I could think of and everything they could, too. It does include unloading, conveying, drop points, cooling towers, generators, fire pumps, roads, coal piles?anything that we thought might kick up any kind of particulate at all, we included it.?

After all of the questions were answered, Byrnes said she thought the session served its purpose of providing information on the permitting process. ?I felt like it went very well. We got a lot of good, detailed questions. I feel really confident that we helped people understand what we reviewed and hopefully set some people at ease,? Byrnes said. From the questions given, she said, it was evident that people had been reading the DEQ Web site and following the information in the newspaper. Byrnes said that after the public comment period is completed, the DEQ would consider additional information and questions, which may come up before making a final determination. ?There could be something that comes up during this public co

mment period that we didn?t look at and we will have to go back and look at it. All these things will be taken into consideration in the final decision,? she said. Many things are not considered in the DEQ?s decision, such as type of fuel used or where Wolverine purchases the fuel, but meeting emissions standards must be met regardless of what fuel is used or where it is purchased. ?They have emission limits that (Wolverine) has to meet and they are based on the best available control technology and they have to meet these emission limits. It doesn?t matter where they are getting their fuel from,? Byrnes said.

The draft permit is posted on the DEQ Web site at (www.deq.state.mi.us). Written comments received during the comment period will be considered in the final permit decision and must be received by November 24, 2008. Those comments are to be sent to Ms. Mary Ann Dolehanty, acting permit section supervisor, MDEQ, Air Quality Division, P.O. Box 30260, Lansing, Michigan, 48909-7760. Comments may also be submitted from the webpage http://www.deq.state.mi.us/aps/cwerp.shtml (click on ?Submit Comment? under the Wolverine Power Supply Cooperative, Inc. PTI No. 317-07 listing).