Emissions – What level?
Jun 5, 2021
What is the proper amount of emissions to allow from industrial and chemical plants and how are emissions traded for jobs?
I was appalled when I compared what West Virginia’s Department of Environmental Protection expected to allow for the proposed West Virginia Methanol plant in Pleasants County, near the Ohio River, with what was achieved 30 years ago for a new plastics plant in New York.
About 1990, GE built a new plant in New York State. As I remember the Geloy plant yearly produced 30 million pounds of plastic and only one pound of emissions. The entire plant was inside a new building. There was a continuous air monitoring system, which sampled air at several critical locations. If the monitor detected more than 1 part per million of acrylonitrile, an alarm sounded and corrective action was taken.
Contrast that with the methanol plant under review by the WV DEP.
According to a Gazette-Mail article April 30, 2021:
“The proposed facility has the potential to emit 91 tons of carbon monoxide, 92 tons of nitrogen oxides (poisonous, highly reactive gases), 54 combined tons of three different kinds of particulate matter, and 11 combined tons of the known or probable human carcinogens formaldehyde, acetaldehyde, benzene and 1,3-butadiene, according to West Virginia Methanol’s permit application.”
West Virginia Methanol will emit hundreds of tons of emissions compared to one pound of emissions achieved 30 years ago at the GE Geloy plant in Selkirk, N.Y. These emissions do not even include methanol but only byproducts of the process.
Since none of these separate byproducts individually exceeds the 100 tons per year required by the state to be considered a “major” emitter, no emissions modeling is required. One regulated stream will be 92 percent of a “major” emitter and a second will be 90 percent. When added together the two streams clearly exceed 100 tons. This appears to be a clever attempt to build the first of several possible plants and never be considered a “major” emitter.
I am familiar with butadiene, one chemical byproduct to be emitted by the methanol plant, which I used as a student and at GE Plastics, Washington plant. The plant used barge loads.
To compare the butadiene emissions from a plant that used massive amounts as a raw material to emissions of the proposed methanol plant that produced butadiene only as a byproduct, I looked at the WV DEP public records for the SABIC plant, formerly GE Plastics. For 2014 SABIC reported 0.5 tons per year of butadiene emissions. The methanol plant will be permitted to emit 11 tons of a mixture of four suspected carcinogens, one of which is butadiene. If all the mixture is butadiene, then the new construction will be permitted to emit 22 times more butadiene as a byproduct than the SABIC plant, which used butadiene as a feed stock, actually emitted in 2014.
I only found the 0.5 ton of butadiene after hours reading public records for the SABIC plant. Most appeared to be 60 pages of yearly documentation that correct procedures were followed. None had any numerical data about what was emitted. Only one Certified Emission Statement dated 7-11-2014 actually listed data. A Hazardous Air Pollutants (HAPs) Worksheet, filled out by hand, indicated 0.5 tons of butadiene was included in the combined total. The total also contained 3.7 tons of acrylonitrile, 2.72 tons of cumene, 3.87 of methyl methacrylate, and 22.18 tons of styrene plus other minor emissions. In 2014 SABIC reported emissions of 34.06 tons of combined Hazardous Air Pollutants.
In my opinion:
1) All emissions from the proposed WV Methanol plant should be added together in determining if the emitter is “major,” especially since two of the byproduct emission streams are each over 90 percent of the “major” 100 ton limit. In addition the emissions of methanol should be included in the “major” limit calculation.
2) Emission modeling for the methanol plant should be completed, even if it is not legally required.
3) Continuous fence line monitoring should be standard for all new plant construction or major modifications. If this is not done by the plant owner, DEP should have mobile monitors that are periodically placed near the fence line and the data made public. The public should be able to monitor anywhere outside the plant boundaries.
4) Best available technology should be used for new construction and major modifications.
5) Building several small plants as a substitute for one large plant to circumvent the emission requirements for the single large plant should not be allowed.
6) Annual emissions for each plant and each chemical should be easily accessible to the general public. This would lead to a clearer public understanding of the trade off between the health hazards of too lax and the economic hazard of too restrictive legislation.
Warren Peascoe is a Ph.D. chemist, retired from Uniroyal and GE Plastics,