BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ Email: BREDL@skybest.com
December 3, 2001
Fred Langenbach,
P.E.
Division of Air
Quality
1641 Mail Service
Center
Raleigh, NC
27699-1641
Re: Trigen
Biopower– North Cove,
McDowell County, NC Draft Permit No. 05600T08
Dear Mr.
Langenbach:
On behalf of the
Blue Ridge Environmental Defense League and our
members in McDowell County, I write to comment on
the Trigen Title V permit. We hereby request that
before the permit is issued a public hearing be
held for the benefit of affected residents living
in North Cove and other communities in McDowell
County.
General
Comments
Trigen’s
request for PSD avoidance notwithstanding, we
request that DAQ testing should include all
criteria pollutants emitted from the stack. Also,
a thorough evaluation of hazardous air pollutants
should be done and stipulations for the control
of HAPs should be included in the Title V permit.
The burning of waste material and the special
atmospheric conditions found in mountain
communities require additional measures of
testing and record keeping to protect public
health and to ensure compliance with all state
and federal laws.
Re-testing for PSD
avoidance must be conducted before the Title V
permit is issued, not “within six months of
permit issuance.” A facility must comply
with air quality requirements at all times.
Issuing the permit before determining whether the
facility may avoid PSD would exempt violations
which occur before testing can be completed. The
DAQ cannot permit a facility to operate as a
minor PSD before certifying it as such.
Specific
Comments
Permit Section
2.1.A .4. Emission Limits for Criteria Pollutants
Are Unenforceable
As a practical
matter, the emission limits for PM-10 and other
pollutants are not enforceable. Non-compliance
with or a change in state toxics rules could
affect emissions but affected citizens would have
no remedy in this matter. The draft permit
states:
| “In
order to avoid applicability of 15A NCAC
2D .0530 (g) for major sources, boiler
(ID No. WBES-1) shall discharge into the
atmosphere less than 250 tons each of
PM-10, sulfur dioxide, nitrogen oxide,
carbon monoxide, and VOCs per consecutive
12 month period.” |
The
maximum PM-10 limit is based on NC Toxic Air
Pollutant limits and an estimate of heat content
in burning carpet waste. The equation used to
determine allowable PM-10 emissions from the
burning of wood and carpet waste is:
Ec
= [(0.38 Qw) + (0.51 Qo)] /
Qt
The total
particulate emission rate (Ec) is
directly proportional to carpet waste heat input
(Qo), therefore an increase in the
allowable amount of carpet waste burned will
increase the annual tons of the criteria
pollutant PM-10. According to the DAQ air permit
review, carpet waste heat input (Qo)
is a variable “dependent on the actual
amount burned at any time.” The Title V Air
Permit Application Review states further:
| “The
allowable emissions rate for carpet waste
was determined based on the allowable
carpet waste input to the boiler of 1370
pounds per hour times 14,000 Btu per
pound of carpet equates to a maximum of
19.18 million Btu per hour. Applying this
heat input to the equation in 2D .0503(c)
provides an allowable emission rate for
the carpet of 0.51 pounds per million
Btu.” |
The
allowable carpet waste emissions rate is included
in the draft permit as a constant (0.51) as
determined by this equation:
Eo
= 1.090 Q-0.2594
The carpet waste
heat input (Q=19.18 mmBtu/hour) is a factor of
the maximum amount of carpet burned (1370
pounds/hour) times the carpet heat content
(14,000 Btu/pound). The 1370 pounds per hour, or
6000 tons/year, is based on toxic air pollutant
regulation 15A NCAC 2Q .0701 and, according to
the draft permit, is state enforceable only.
A change in state
rules, a new estimation of toxic air emissions,
or a re-evaluation of carpet waste heat content
could change the allowable annual tonnage of
carpet waste burned in Trigen’s boilers.
This would affect the PM-10 output because the
emission rate is determined in part by the
parameter for carpet waste emissions (Eo).
SO2 and other criteria pollutants
would also be affected.
The DAQ has
already acknowledged that the facility has the
potential to exceed 250 tons per year of NOx
and CO. A DAQ inspection on February 10, 2000
found a CO level of 6,328 ppm, indicating
potential annual CO emissions of 4,200 tons.
According to the inspector, at that time the
plant appeared to be operating within permit
requirements. As written, the draft permit makes
it difficult or impossible for citizens to
determine if Trigen is in compliance with
emission limits.
Permit Section
2.2 Permit Shield Not Properly Applied
The draft permit
states that Trigen is shielded from New Source
Performance Standards, 40 CFR 60 Subpart
Db—Standards of Performance for
Industrial-Commercial-Institutional Steam
Generating Units— because plant
modifications which have occurred since 1985
escape the definition of modification under 40
CFR 60.15. However, in a decade and a half the
aggregate costs may well have exceeded 50% of
fixed capital costs. The overfire air system
alone reportedly cost $600,000. The regulation is
silent on the timing of modifications and makes
no exemption for alterations occurring over time.
The permit shield
should not exempt the Trigen facility from
applicable requirements under 40 CFR 60.40b . If
the plant was not designed for carpet waste as an
alternative fuel, it is subject to 40 CFR 60.14
(e)(4) and 60.1 Subpart A.
| 40 CFR
60.14 (e) The following shall not, by
themselves, be considered modifications
under this part: (4) Use of an alternative
fuel or raw material if, prior to the
date any standard under this part becomes
applicable to that source type, as
provided by § 60.1, the existing
facility was designed to accommodate that
alternative use. A facility shall be
considered to be designed to accommodate
an alternative fuel or raw material if
that use could be accomplished under the
facility’s construction
specifications as amended prior to the
change. Conversion to coal required for
energy considerations, as specified in
section 111(a)(8) of the Act, shall not
be considered a modification. [emphasis
added]
|
Moreover,
the burning of carpet wastes at the Trigen plant
constitutes a change in method of operation and
carpet waste certainly adds pollutants not
previously emitted.
| 40 CFR
60.2 Modification means any physical
change in, or change in the method of
operation of, an existing facility which
increases the amount of any air pollutant
(to which a standard applies) emitted
into the atmosphere by that facility or
which results in the emission of any air
pollutant (to which a standard applies)
into the atmosphere not previously
emitted. |
Therefore,
we believe that New Source Performance Standards
apply to the Trigen facility.
Respectfully
submitted,
Louis
Zeller
Title V Fact
Sheet
BREDL
comments on other Title V permits
|
