Part two of DEQ questions and answers

by Richard Lamb, Advance Editor

Part two of the question and answer session from the October 1 meeting drew out more information about Wolverine Power?s proposed 600-megawatt power plant. The plant is proposed to be built in Rogers Township, just south of Rogers City. The Department of Environmental Quality?s (DEQ) Air Quality Division (AQD) hosted a four-hour informational session at Rogers City High School (RCHS) where some of the 18 DEQ staffers present answered questions posed in the public forum about the DEQ?s draft permit for the power plant issued last month. Former Rogers City mayor Dave Nadolsky served as moderator. The questions presented below may be paraphrased for clarity and length. The person from the DEQ answering the question is indicated in parenthesis.

Question?If a coal plant exceeds emissions is it immediately shut down?

(Melissa Byrnes, environmental engineer, permit section)??They have to submit reporting records and keep records and then we review them. They have to let us know if they have any excedants at any time.?

(William J. Rogers, Jr., environmental quality analyst)??I don?t have the authority to tell a plant to shut down. But I can tell them that they are operating in violation of their permit and we can take enforcement action about that. It could be a civil suit or it could go as far as criminal action.?

Question?Is there any documented or identified need for the amount of power that this plant will generate?

(Julie L. Brunner, P.E., senior environmental engineer, permit section)??The Michigan Public Service Commission has been doing studies for a number of years about energy needs currently and in the future for the state of Michigan. The latest one was the 21st Century Energy Forum, which looked at how much we would need. It has been looked at. They have identified a need for additional power. They tried to identify what forms?natural gas is a possibility, coal-fired power is a possibility, nuclear as a possibility, alternative energy as a possibility and is something that they really want to promote. So that has been looked at least twice in the past five years.?

Question?How do you integrate public comments both written and spoken into your decision-making process and does that become part of the record?

(Mary Ann Dolehanty, acting supervisor, permit section)??All of the public comment received is reviewed. As a group we make note of them. If there are any areas that we have identified that require additional review, we will undertake that additional review. It is a very important part of the process that we receive comment and that we conduct additional review on the comments that are received by the public.?

Question?What is the next step in this process?

(Dolehanty)??The comment period will take until November 24, that will be the end of the formal comment period. It will take as much time as we need in order to evaluate all of your comments. It could be a week, or it could be several months. I don?t actually anticipate it being a week, I actually anticipate us receiving a number of comments that we will have to revisit. And depending on whether or not we have to do additional review, it could take some time after that before a final decision is made.?

Question?Has anyone from the DEQ visited sites, which use similar technology proposed by Wolverine?

(Dolehanty)??Yes. There are several of us here, Melissa is one, I am one and there is at least one other permit engineer who has visited the Tampa plant that uses this relatively new technology for full-scale base-load facilities. We were very impressed with the technology. In fact as part of our review here we did ask the company to review this technology to determine whether it would be appropriate here. When I say appropriate, our review has to be based on federal law as determined by cost.?

Question?Is it true that circulating fluidized bed (CFB) boilers coal-fired power plants have more start ups than conventional coal plants and that at start ups the emissions are higher than normal?

(Byrnes)??They are limited in their permit to the number of start ups and shut downs.? (James G. Haywood, senior meteorologist, modeling and meteorology unit) ? ?I think I have pointed out several times that when I do the modeling, I look at a worst case scenario and we always ask, when an applicant comes in, that they look at different scenarios of emissions. It might be half load, 75 percent, 100 percent, start up or shut down. In this particular case we found out that the worst-case emissions were at start up and shut down. So when we modeled, we modeled everything based on their start up and shut down emissions which is much worse than what they would be doing during a normal load.?

Question ? What is the scope of the authority of the DEQ and does the DEQ have the authority to ignore or go beyond the regulations established by the state government and federal government?

(Haywood)??We cannot individually, arbitrarily do less than what is required by law and we cannot individually, arbitrarily go beyond what is required by law. The state does, however, have the authority to go beyond what the Environmental Protection Agency (E.P.A.) requires us to do. In other words, the E.P.A. sets the base level. The state does have the authority to be more stringent than that. In most cases we adopt whatever the E.P.A. requires us to do. But there are a lot of cases where we are more stringent than the E.P.A. requires.?

(Robert Sills, toxicology specialist)??We do have rules and regulations for air pollutants in regards to health risks. The regulations say that nobody can emit substance that would pose a health risk for non-cancer effect and for cancerous effects for not more that 1 in 100,000 risk level for cancer for people at the point of maximum impact. For this particular facility none of those substances that were emitted posed had a level that was close to that. In total the risk was five in a million. ?We also have the ability to look at all the substances as a mixture and we have looked at that. I don?t see any indications that they would pose a health risk as a mixture?. We are restricted by regulations, but yet they are very broad and they give us authority and we exercise that authority to the extent we can.?

Question?What are some possible exemptions to what Wolverine can burn and do they have to say they are going to burn other fuels?

(Byrnes)??They can use the exemptions for certain kinds of fuels and equipment. That is not going to increase their emissions. For instance Lafarge is using 20 percent plastics instead of coal. That was evaluated and from the plastics that they are getting is actually decreasing their emissions. At their own risk they are using the exemption. We told them it is in their best interests to get a permit and have us review it and we are in the process of (reviewing) that?we could go out there at any time and test it to make sure that it is truly exempt and if it is not, then they would be in enforcement action.? Question?Do the permit conditions protect the public from the handling of all fuels including petroleum coke?

(Byrnes) ? ?Yes there are emissions limits in the permit for fugitives for truck traffic for the handling of fuel. They have to abide by those permit conditions. Again, if they are not the districts could send them a letter of violation or go into that whole (enforcement) process. There are conditions in the permit for that.? Question ? Have you considered the health effects of emissions on the local population and the state population?

(Sills)??Of course we have considered the health effects on the local population. The impacts of an air emissions source is going to be greatest near the point of emission because the further it travels the more it gets dispersed and diluted?If we can be protective to people the closest to the facility, which we are, then we don?t need to look further because we feel that by default, everyone further away is going to be protected even more so.?

Question ? What are the emissions that promote respiratory stress?

(Sills) ? ?The emissions from a facility like this are varied and at some level of exposure, some of these substances can cause respiratory irritation and in some cases can cause cancer at high enough levels of exposure so of course we account for that. We look at those compounds and their effect individually, and as I said, we look at them collectively to see if they can have some additive combined impact?We have levels that are safe and protective enough for everyone to assure those (complications) will not happen?even at maximum exposure for a full lifetime.?

Question ? What is the timeframe you use for mercury exposure?

(Sills) ? ?We look at mercury exposure both inhalation and its long term environmental accumulation. We look at what would be the air concentration at the point of maximum impact and we make sure that air concentration cannot be harmful by just directly breathing it in the air because mercury can cause neurological effects. If you have enough exposure it can cause tremors, uneven gate. The air concentration was 50,000 times lower than the concentration that we use to protect against that effect. So it is an extremely low inhalation exposure. For the concern about long-term emissions and deposition and accumulation in the environment and accumulating in fish, we look at that over a 30-year operation of a facility at maximum operating conditions and accumulation?I don?t think we are underestimating when we look at the long-term effects of mercury.?

Question ? Is this a hot spot for cancer or mercury and has that been considered?

(Sills) ? ?I am familiar with the concern that there can be some elevated mercury levels in some parts of the state but I am not aware that this is considered a hot spot. All of the data that I have looked at for mercury in fish in the lakes for this part of the state are relatively low. If you go down the Alpena and Lafarge with Lake Besser and part of the Thunder Bay River system we have mercury data there to indicate it is elevated and it is above that .035 part per million level. There are other lakes near Lafarge that have some mercury data. Long Lake has a relatively low mercury level. We are working with Lafarge to find out how much is their contribution to the mercury in the lakes in this area. That is a separate issue on its own. I don?t think this facility (Wolverine?s proposed power plant) is going to have a significant overlap and impact.?

Question ? Can local planning commissions or zoning commissions take measures that are more protective than DEQ standards?

(Sills) ? ?I?m not

sure what the answer to that is. I?m not sure what their authority is and how far that reaches.?

Question ? The local planning commission, as of this moment, has not approved the use of petroleum coke as a fuel for the power plant, but the applicant has petroleum coke in their application. Could the DEQ?s approval of the air quality permit supercede local planning commissions current decision to not allow petroleum coke in the boilers?

(Byrnes) ? ?What is in the permit is our state requirements. So they have to meet all the state regulations. We have looked at the emissions from petroleum coke.?

(Dolehanty) ? ?What the state looks at are somewhat independent from local regulations. We have received information from local community members that the planning commission did not approve as part of their overall process the use of pet coke. We are aware of that but our review did include it. Our review in no way overrides or supercedes the planning commission process. We are an independent reviewer. We are looking at it and have review it for the worst case emissions, the health risks associated with it and have included it as part of our draft proposal for the Wolverine permit. What the reviewed process is for the company to go back to the planning commission for the approval of pet coke is independent of our review.?