By way of post number three in the continuing on the thread about comments provided to DEQ on the scope of work from the poultry litter working group, here are excerpts from another stakeholder’s comments.
“…I thoroughly agree with the feedback that you are receiving from the National Parks, the Southern Environmental Law Center, the Shenandoah Valley Network and others regarding your focus exclusively on a 55-MW Fibrowatt incineration facility, and your decision that the study group should ignore air emissions. Your minutes from the comments made by both members of the Advisory Group and the public during the March 28th meeting indicate that "emissions" were mentioned 22 times either directly or indirectly (e.g. indirectly via the word "health"). If you continue to dismiss the thoughtful comments of the members of the Advisory Group and the public, you risk the appearance that a final decision has already been made, the Advisory Group's analysis will be ignored, and that the DEQ's decision will be in Fibrowatt's favor. I am sure that you want to avoid that impression, especially since a proposed scalable, NRCS best management practice (BMP) called animal waste gasification is a [low-emission], economically-viable alternative to incineration.
I am still trying to obtain a copy of the comments sent by the Southern Environmental Law Center and the Shenandoah Valley Network, as well as a copy of the scope I can review and summarize.
What’s telling in this note is the DEQ’s decision to delete a review of air emissions from this scope. Emissions are obviously an important element of the discussion…that is where acid rain comes from, as noted by the NPS in the comments they sent, and as this writer says, emissions were discussed multiple times in the advisory group’s meetings.
Whether or not the emissions released by a proposed plant of this type are within a range that DEQ can acceptably permit, it is important for the public to be made aware of the risks – early and often. DEQ’s deferral of discussion on this point raises the questions the writer above proposes – and may even be a dereliction of responsibility.
Here’s a summary from a previous post about the emissions that have been authorized in the other Fibrowatt permits:
“…according to its air permits, the plant is a major source of particulate matter, sulfur dioxide, carbon monoxide, nitrogen oxides and hydrogen sulfide.” In the permit itself, several other emissions are noted, including sulfuric acid and hydrochloric acid.
As for the risks associated with these emissions, I consulted the Wikipedia articles on them, and the results are bulletized below. It turns out that many of these compounds are greenhouse gases, meaning they will impact visibility and have a long-term impact on the larger environment. But some of them are used as industrial corrosives and are also identified as health risks.
• “Sulfur dioxide is associated with increased respiratory symptoms and disease, difficulty in breathing, and premature death.”
• “Sulfuric acid is a component of acid rain, and is highly corrosive.”
• “Hydrochloric acid - Both the mist and the solution have a corrosive effect on human tissue, with the potential to damage respiratory organs, eyes, skin, and intestines.”
• “Carbon monoxide is a major atmospheric pollutant in some urban areas, chiefly from the exhaust of internal combustion engines (including vehicles, portable and back-up generators, lawn mowers, power washers, etc.), but also from improper burning of various other fuels (including wood, coal, charcoal, oil, paraffin, propane, natural gas, and trash).”
• Finally, nitrous oxide was also noted to be a greenhouse gas
Back to the comment from the writer at the beginning of this post. Maybe the correct name for this advisory group - I've posted this before - is "Virginia DEQ's Fibrowatt Site Selection Communication Strategy Group" - especially if it's one where Virginia DEQ is talking at their advisory partners rather than listening to them.
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