The deadline is fast approaching to submit comments to the Mass. Department of Environmental Protection regarding the wood-burning power plant proposed for East Springfield. April 29 is the close of the public comment period on a draft air-quality permit for the plant, proposed by Palmer Renewable Energy. A copy of the draft permit can be found on the DEP’s website; comments can be sent to marc.simpson@state.ma.us.
This week, several opponents of the project—Stop Toxic Incineration in Springfield, the American Lung Association and the Pioneer Valley Asthma Coalition—submitted the following joint letter to DEP outlining their grave concerns about the potential effects the plant could have on public health and the environment. (STIS also has a prepared letter on its website that concerned residents can send to the DEP.)
April 21, 2011
Marc Simpson
Air Quality Permit Chief
Department of Environmental Protection
436 Dwight St.
Springfield, MA 01103
Dear Mr. Simpson:
We, the undersigned, respectfully submit our comments pertaining to the Draft Air Quality Permit for Palmer Renewable Energy.
Stop Toxic Incineration in Springfield affirms that the primary purpose of air quality regulations and permits are to protect the health of MA residents. If not, then the whole process is an exercise in futility. State agencies, health groups and environmental groups that recognize that current federal standards are NOT protective of health; in fact, even DEP is on record as asking EPA for a lower PM standard than the current NAAQS. Even as they are, these federal standards were originally set to protect healthy populations, NOT Springfield residents with documented health issues in an Environmental Justice Community, and NOT in a region that is close to NAAQS thresholds, or out of attainment, for important pollutants.
Even if this incinerator meets all currently established standards, area residents will suffer from degraded air quality and related health effects. This incinerator will be adding literally tons of hazardous air pollutants, tons of the ozone precursors- NOx and VOCs, 90 pounds of lead, as well as 42 tons of particulate matter both at stack height and at ground level, including highly hazardous diesel particulate matter due to the high number of trucks involved. So to be clear, granting this permit simply establishes statistically generated goals to be met by statistically processed emissions data. This is NOT the same as setting health protective standard with commensurate health monitoring.
The relationship between short-term spikes in air pollution and increased rates of respiratory illness and death is well established. These spikes, such as the one that occurred on April 12, are “hazardous” days for air quality in Western Massachusetts – a designation the EPA AirNow site defines as “health warnings of emergency conditions” when the “entire population is more likely to be affected.” These regular events need to be addressed before MA DEP considers permitting what will be one of the largest, if not the largest, sources of particulate matter in the four counties of Massachusetts, when air quality is already so degraded.
We ask that permitting be suspended until the EPA has finalized new air quality standards, including those for fine particulate matter, and until the Springfield Public Health Council has completed its site assignment process.
That being said, we request that the final permit, if issued, take the following into consideration:
1. We ask that DEP re-review modeling and emissions standards using a higher, more reasonable moisture content of the proposed fuel. This assumption of average 40% moisture content appears to unduly influence the assessment process.
2. Using the maximum 24 hour average for PM 2.5 and CO for modeling, monitoring and emissions cap calculations ignores the shorter time frame of biological effect and local daily meteorological activity. A 24 hour averaging period for many pollutants is NOT health protective. When you ignore hourly data, the spikes, such as the one that occurred on April12th, that actually affect health go unnoticed. We ask that this permit utilizes hourly measurement for all pollutants, especially those that have a respiratory health effect, and apply relevant limits to those measurements. We also ask that hourly data is made available on any web publication of emissions data.
3. We recognize that the facility claims not to be a major source for HAPs, but given that the filterable PM limit set in the permit is more than 10 times what is achievable and required by EPA for major source facilities, we ask that the air permit require PRE to control filterable PM to 0.0011 lb/mmbtu, the level required by EPA’s major source MACT standard.
4. We ask that the DEP recalculate and remodel the effect of facility HAPs emissions, taking into account DEP’s own ambient HAPs data collected at Westover Air Force Base. DEP should acknowledge that the region is currently well over the EPA limit for several pollutants (acetaldehyde, benzene, carbon tetrachloride, formaldehyde, and polycyclic organic matter (POM)). Allowing a new source of such emissions, even if considered a minor new source, flies in the face of protecting the public health.
5. We ask that PRE be required to pay for health metric monitoring in surrounding communities. This should include, but not be limited to, asthmatic attack rates at school, hospitalizations for cardiac and respiratory incidents, and missed school days. These measurements will be used for future review of emissions controls efficacy and in considering the need for a plant shutdown.
6. We ask that PRE be required to pay the city of Springfield for the cost of an independent, third party to monitor the CEM stream for the life of the incinerator to ensure there are no air quality violations. If the analysis of pollutants provided to the state by developers has been incorrect, or if there are air quality violations (to be determined in the air quality permit), then the city of Springfield will have the authority to close the plant until it can meet the standards they set forth in their analysis. This is critical since an independent, third-party analysis and an environmental impact report were never required, and since this developer avoided more stringent regulations because of non-major polluter status, and since Springfield and Pioneer Valley air is already so compromised.
7. We ask the permit include a mechanism whereby the plant will be taken offline during periods when ozone or particulate matter reach unhealthy levels, such as have occurred several times this year already. This mechanism must require including members of the Springfield Public Health Council.
8. We ask that the permit include a notification system to alert Springfield Public Health Council members whenever plant emissions violate permitted levels. In addition, members of the Springfield PHC shall be included in violation resolution and negotiation discussions between MA DEP and PRE.
9. With regards to fuel supply, we request that:
a. MA DEP acknowledge that there has been no verification of the amount of fuel available to fuel this incinerator as defined in the permit. The estimated amount required may well be inadequate. The sources are undefined, unidentified and dependent on economics and logistics. Charts showing available quantities include tons that are already utilized for competing needs. Information provided is ambiguous and often contradictory. This alone begs for additional permitting steps, or a new permit outright.
b. MA DEP require intensive sampling and inspection of potential wood supplies and documentation of the results BEFORE the permit is approved. MA DEP should require that PRE supply a list of prequalified suppliers BEFORE the permit is approved. All testing that is required after the permit is approved should include not only municipal and private wood yards, but all sources, and all truck loads from all sources. All testing, inspections and sampling should be performed by independent, third parties, using unannounced schedules.
c. MA DEP must include methods by which out of state sources can be guaranteed to comply with clean fuel standards. The testing schedule and protocol must acknowledge that out of state sources are not controlled by MA standards or subject to state inspection.
d. MA DEP must address all issues related to an “off-site wood storage/processing yard” as required by the NPC Certificate of Nov. 19, 2010. All specifications for the operation of the off-site wood storage/processing yard must be included in the permit and the permit must address the same control mechanisms as those required of the onsite storage shed.
e. MA DEP should remove from this permit any and all suggestions that sampling/testing/accounting/inspections/ or frequency of such can be reduced over time. This facility requires strict monitoring throughout the life of the plant. There should be no opportunity for the permittee to request changes. Example: #15 “The permittee may request a change in frequency of testing and in the type of constituents tested once enough data has been generated to determine the consistency of the results.”
Sampling frequency should increase over time, since as the fuel supply tightens, the incentive to use construction waste wood will increase.
f. MA DEP must draw a hard line with no post-startup alterations to the fuel specifications. There must be no option for future use of forestry derived wood fuel, including wildlife management harvests. There must be no options for future use of tire derived fuel, telephone poles or C and D derived wood, all of which have been considered by Palmer Renewable Energy. Clean non-forest derived wood fuel availability must be verified before this permit is approved to prevent a need to resort to such alterations of the fuel specifications.
g. MA DEP must verify the content of moisture in the proposed wood supply. Estimates of 30% – 50% are too low. Clean green waste wood typically contains 45% – 50% moisture.
Moisture content effects the efficiency of the plant and the carbon dioxide emissions. It also has an impact on the number of tons required to fuel the plant. Verification is essential.
h. MA DEP should prohibit the use of pallets as a source of clean fuel. Pallets are known to be reused. There are no provisions for tracing the origins of ground pallets which may well have been contaminated by toxic materials stored on or near them.
10. Page 37, point 17 in the permit states:
“Any revision of the allowable emission rates shall not exceed levels at which the best available control technology (BACT) were evaluated, shall not exceed the level at which facility impacts were modeled, and shall not be a result of a physical change at the facility.”
We ask that any such language that limits the state’s ability to revise allowable emission rates be eliminated to assure that the state has every recourse to reduce emissions if modeling was inaccurate, better technology is available, or if health effects warrant such reductions.
11. The permit must remove any reference to limiting the duration of air monitoring and reporting. Air monitoring and on-line reporting must be mandatory for the life of the incinerator.
Thank you for addressing these issues, and all others submitted by interested parties.
Sincerely,
Stop Toxic Incineration in Springfield
Stuart Warner, Founding Member
swarner@wnec.edu
American Lung Association in Massachusetts
Katie King, Health Promotion and Public Policy
kking@lungne.org
Pioneer Valley Asthma Coalition
Matthew Sadof MD, Chair
matthew.sadof@bhs.org
