Greg Helms' SEPA Comments

Submitted to Shelton Blog by Greg Helms

Letter to City of Shelton urging a determination
of significance for Solomon/Simpson

October 7, 2010

Mr. Jason Dose
Senior Planner
City of Shelton
525 W. Cota Street
Shelton, WA 98584

Dear Mr. Dose,

I am writing to you today to express my concerns regarding the “Solomon Renewable Energy Company LLC” SEPA application before your office. Simpson Lumber Company originally submitted the application in May of this year for a 31 MW cogeneration plant that was to replace an aging process steam plant.

Simpson Lumber Company gave a public presentation about how the new system would be so much better for the downtown region and that overall air quality would be improved. In the subsequent two months a new entity “SREC” has suddenly appeared, a new SEPA application filed in August and news that the existing Simpson process steam boiler would not be removed has taken the citizens by surprise. Taken together with the impending Adage project and it begins to look like the city of Shelton will be home to well over 1 million tons of wood incineration per year.

Despite state assurances that the air in Shelton meets air quality standards most of the year it is common knowledge that Shelton is home to some of the worst air inversions during both the winter and summer months and that the air downtown is hazardous during these times. Taking the 2007 emission inventory numbers for both Simpson and Olympic Panel we see that the “current” state of air pollutants (for a selected few pollutants) in the downtown bowl includes:

Simpson Lumber current emissions
Total Particulatel	136 tons per year (tpy)
PM10	61 tpy
PM2.5	48 tpy
Nitrogen Oxides (NOx)	60 tpy
Volatile Organic Cmpds (VOC)	14 tpy
Acetaldehyde	16.5 tpy
Carbon Dioxide (CO2)	106,000 tpy
Hydrogen Chloride (HCl)	12.6 tpy
Carbon Monoxide (CO)	258 tpy
Total Hazardous Air Pollutants (HAP)	28.7 tpy

Olympic Panel Products
Total Particulate	103 tpy
PM10	T45 tpy
PM2.5	23 tpy
Volatile Organic Cmpds (VOC)	23 tpy
Propane	91 tpy

Overall this does not include all of the current diesel truck traffic as well. I realize that the Simpson site has been a heavy industrial site since the inception of the city of Shelton however the idea that adding to the current load of pollutants is somehow safe or advisable is ludicrous.

The idea that a new entity “SREC” can come in and install a 31 MW biomass incinerator without removal of the current Simpson burner is not acceptable. The current pledge to use the original Simpson burner only in times of need does not preclude them from operating it 24/7 if they so choose.

Air pollution is a cumulative phenomena and the very real possibility exists that in addition to the already high levels of pollutants being dumped into the Shelton airshed that the “SREC” facility AND the Adage facility could be adding the following to the mix:

SREC proposed emissions for a 31 MW biomass plant (from the NOC application to ORCAA)

Total Particulate	67 tons per year (tpy)
PM10	38.2 tpy
PM2.5	28.6 tpy
Nitrogen Oxides (NOx)	248 tpy
Sulfur Dioxide (SO2)	147 tpy
Carbon Dioxide (CO2)	265,000 tpy*
Hydrogen Chloride (HCl)	9 tpy
Carbon Monoxide (CO)	248 tpy
Total Hazardous Air Pollutants (HAP)	23.1 tpy

* (my conservative estimate due to the fact that they are not required to report the CO2 emissions based on the false assumption of carbon "neutrality")

Whereas the Adage proposed emissions for a 60 MW biomass plant (from the NOC application to ORCAA):

Total Particulate	195 tons per year (tpy)
PM10	98 tpy
PM2.5	97 tpy
Nitrogen Oxides (NOx)	248 tpy
Sulfur Dioxide (SO2)	149 tpy
Carbon Dioxide (CO2)	550,000 tpy*
Hydrogen Chloride (HCl)	9.7 tpy
Carbon Monoxide (CO)	248 tpy
Total Hazardous Air Pollutants (HAP)	18.5 tpy

It is very interesting to note the discrepancies in the amounts of pollutants between the SREC and the Adage applications. The SREC facility is roughly half the size of the Adage proposed facility yet the numbers achieved via the “modeling” of the plants are extremely different in terms of the ratios when you account for the factor of 2. Both will utilize identical fuel sources and both will employ very similar pollution control technology.

It is obvious that we, the citizens, should be VERY skeptical of any of the data presented in either application. How can it be that a plant twice the size emits the same levels of certain pollutants (i.e. CO and NOx levels). The particulate numbers for the SREC facility are also quite suspect as they are too low compared to the Adage numbers, especially as they will be employing an electrostatic precipitator vs the filter baghouse for Adage. When accounting for the difference in size the SREC facility will emit 43% less PM2.5 than the Adage facility yet it will use a stoker type boiler and an electrostatic precipitator, equipment that is generally considered by most experts to be less efficient than a fluidized bed burner and a baghouse for particulate capture. Either the modeling numbers are not correct or both applications are fraudulent. It is also necessary to factor in the potential for upwards of 300 additional diesel tractor-trailer trips through the heart of Shelton if the Adage facility is to be permitted.

It is interesting to note that both Adage and SREC will be employing what is known as BACT (Best Available Control Technology) rather than MACT (Maximum Achievable Control Technology) for control of the listed pollutants due to the fortuitous sizing of the plants to escape having to pay for more expensive equipment. The SREC application even lists the “economic justification” in the Appendix B (BACT Analysis) for the use of BACT stating “If the cost per ton of pollutant reduced for a particular technically feasible control system is disproportionately high compared to the cost per ton in recent BACT determinations for other sources in the same source category, the control technology is deemed not cost effective and can be rejected as economically unjustifiable”.

In other words if you size your plant to be just under the wire for required MACT controls, then you can emit at close to the maximum levels for the cost of the lower control technology. This in the face of the recent EPA findings that for every dollar that industry spends towards particulate matter control at the MACT level a savings of 5 dollars is realized in public health. Once again, industry profits over the health of the citizens!

The ORCAA application for SREC also states (page 12) that the proposed facility will NOT need a Prevention of Significant Deterioration (PSD) permit due no one pollutant being greater than 250 tons per year. I believe this is due to their request for a separate source determination which would make them a separate entity from either Simpson or Olympic Panel.

It is interesting to note that this “separate” nature is also being used to circumvent any need to comply with acid rain regulations under the Clean Air Act as they claim the facility will be a cogeneration facility that is NOT a primary energy production company and will not be selling more than 1/3 of its power production to a public utility. In addition they claim under their “Separate Source Determination Request” NOT to be a “support” facility to either Simpson or OPP. I am not sure how supplying steam and electric power is not a support facility but this is obviously a legal loophole that will allow Simpson to sell itself power and steam while claiming to be a “separate” entity that is supposed to market clean, green energy (but not too much!). They (Simpson) should not be allowed to evade all manners of regulatory control by using a “shell”.

I would implore you in your capacity as planner to render a decision that this facility represents a SIGNIFICANT risk to the public (especially when combined with all of the other sources of air pollution). Secondly I would hope that you recommend a full and complete EIS to be conducted so that a proper accounting of the levels of pollution can be made. Looking at the discrepancies between the SREC and Adage facilities I would hope that you would render the same decision for the Adage application when it comes up for determination.

Thank you for your attention in this matter.

Sincerely,

Gregory L. Helms, Ph.D.
Scientist and Mason County Resident

Link to pdf version of the letter