Seneca Biomass Incinerator Requests Increase in Pollution Cap

Seneca Bio­mass Incin­er­a­tor Requests Increase in Pol­lu­tion Cap

- by Diane Dietz, July 17, 2013. Source: The Register-Guard 

The own­ers of a 2½-year-old elec­tric­i­ty plant fueled with log­ging scraps have strug­gled to meet clean air stan­dards since the facil­i­ty began oper­a­tions on the out­skirts of Eugene and are ask­ing reg­u­la­tors for a lit­tle more lee­way to pollute. 

Seneca Sus­tain­able Ener­gy, on High­way 99 north of Eugene, has been caught by reg­u­la­tors spout­ing too much car­bon monox­ide, too much dark smoke and too much acetalde­hyde — in con­junc­tion with the Seneca sawmill next door. Plus, there has been uncer­tain­ty about how much fine par­tic­u­late the plant emits.

In addi­tion, the com­pa­ny ran sev­en months with its pol­lu­tion con­trols for nitro­gen oxides switched off, accord­ing to reg­u­la­to­ry reports.

The mishaps brought Seneca fines of $2,200, $2,400 and $9,600, and more reg­u­la­to­ry scruti­ny from the Lane Region­al Air Pro­tec­tion Agency than most com­pa­nies would welcome.

Seneca CEO Richard Re said the wood-fired elec­tric­i­ty plant is still the clean­est in the nation and the com­pa­ny is work­ing its way through the reg­u­la­to­ry issues.

But envi­ron­men­tal­ists who had opposed the plant when it sought its “minor source” air pol­lu­tion per­mit in Octo­ber 2009 con­sid­er Seneca’s request for increased pol­lu­tion lim­its a bro­ken promise.

“It was going to be the clean­est bio­mass ener­gy facil­i­ty around, and they were doing every­thing in their pow­er to keep their pol­lu­tion down,” said Lisa Arkin, exec­u­tive direc­tor of Eugene-based Beyond Tox­i­cs. “They weren’t being truth­ful to the community.”

Seneca secured its ini­tial per­mit from LRAPA by argu­ing it would be a minor source for some of the most plen­ti­ful pol­lu­tants in Lane County’s air. Oth­er­wise, the com­pa­ny would have fall­en under the more oner­ous fed­er­al “new source review” require­ments of the Clean Air Act. Now, with Seneca ask­ing for increased pol­lu­tion lim­its, LRAPA is embark­ing on a “new source review.”

Even­tu­al­ly, the agency will issue a fed­er­al Title V per­mit to Seneca. Title V is reserved for plants emit­ting the most or most dan­ger­ous pol­lu­tion. In Lane Coun­ty, 19 com­pa­nies come under Title V, includ­ing the Kings­ford char­coal plant in Spring­field and the Geor­gia-­Pa­cif­ic chem­i­cal plant and Mur­phy Co. pan­el­board plant, both in Eugene.

For Seneca, the request to increase pol­lu­tion lim­its mean height­ened scruti­ny from LRAPA, fed­er­al reg­u­la­tors and the pub­lic. Part of that scruti­ny comes tonight with LRAPA hold­ing a pub­lic infor­ma­tion ses­sion about Seneca’s request.

It’s not unusu­al for com­pa­nies build­ing new plants to try — like Seneca — to get ini­tial­ly per­mit­ted as a minor source, said Dan Galpern, a Eugene attor­ney with Clean Air Act lit­i­ga­tion expe­ri­ence but no involve­ment with the Seneca per­mit. “Pol­luters often will state that they expect to not be a major source,” he said. “It’s because they may believe it — because they may have over­es­ti­mat­ed the effi­ca­cy of their (pol­lu­tion) con­trol sys­tem. But it’s also true they often are moti­vat­ed to escape the detailed scruti­ny of the Clean Air Act.”

Busi­ness­es want to keep emis­sion lev­els low. “Any time you can stay under a sig­nif­i­cant lev­el (of emis­sions), you’re bet­ter off to do that — if you pos­si­bly can,” Re said.

Fac­ing new requirements

But to the pub­lic, the “new source review” of a pro­posed plant is impor­tant, accord­ing to the Envi­ron­men­tal Pro­tec­tion Agency.

The per­mit is issued before con­struc­tion starts, so air reg­u­la­tors can ensure that air qual­i­ty will not be sig­nif­i­cant­ly degrad­ed, the fed­er­al agency says.

In addi­tion, LRAPA has for­mal­ly told the EPA that LRAPA will rely on “new source review” as a way to con­trol par­tic­u­late pol­lu­tion in Lane Coun­ty, to pre­vent par­tic­u­lates from accu­mu­lat­ing to the stan­dards-­vi­o­lat­ing unhealthy level.

In Lane Coun­ty, par­tic­u­late pol­lu­tion comes large­ly from burn­ing wood, such as wood-burn­ing stoves in the win­ter, for­est fires in the sum­mer, or the Seneca plant or oth­er indus­tri­al sources year-round.

Now that Seneca wants to increase its emis­sions of par­tic­u­late mat­ter from 14 tons a year to 17 tons a year, there­by tak­ing it into the 15-ton-plus def­i­n­i­tion of a major source, it will have to meet a host of new requirements.

The com­pa­ny has to show reg­u­la­tors that it’s using fil­ters, cyclones and oth­er pol­lu­tion con­trols for the low­est achiev­able emis­sion rate. And, the com­pa­ny must buy pol­lu­tion cred­its from some oth­er com­pa­ny in Lane Coun­ty to off­set the 17 tons of par­tic­u­late. Com­pa­nies that stay under the major source thresh­old don’t trig­ger the need to buy offsets.

“It’s quite an incen­tive to be just below the thresh­old,” Galpern said. He added, how­ev­er, that’s not good for the air. “If you have a lot of com­pa­nies com­ing in just under the thresh­old, that can add up to a great deal of pollution.”

Oppo­nents of Seneca’s wood-burn­ing plant were angered that Seneca wasn’t required by LRAPA to get major source per­mits from the start. But LRAPA per­mit writer Max Huef­tle said the agency relied on a guar­an­tee from Wellons, Inc., which made Seneca’s wood-fired boil­er, that the emis­sions would remain below the 15-ton threshold.

When Seneca could not prove it could stay under the thresh­old for par­tic­u­late pol­lu­tion begin­ning in spring 2011, the com­pa­ny didn’t opt to reduce emis­sions by burn­ing slight­ly less wood and gen­er­at­ing a lit­tle less elec­trci­ty — which it sells to the Eugene Water & Elec­tric Board. Instead, the com­pa­ny sought a fin­er test to prove it com­plied with some stan­dards, and it pro­posed rais­ing the lim­its so it would be sure to stay in com­pli­ance in the future.

Fair­ness questioned

To Arkin, ask­ing for new rules isn’t fair. “The rest of us are respon­si­ble for obey­ing laws. If I see a red light, I have to stop. I can’t say, ‘Oh I don’t want to stop at the red light — can you make all the lights yel­low for me?’ ”

Seneca’s pro­posed new lim­it for so-called “par­tic­u­late mat­ter 10,” or PM 10, which is par­ti­cles with a diam­e­ter of 10 micro­meters or less, is 17 tons a year, up from 14 tons a year.

The per­mit would also set the aggre­gate par­tic­u­late emis­sions — includ­ing the coars­er par­ti­cles such as dust — to 24 tons a year. Par­tic­u­late emis­sions are impor­tant, accord­ing to the EPA, because they get into the eyes and res­pi­ra­to­ry system.

Breath­ing par­tic­u­late aggra­vates asth­ma, bron­chi­tis and oth­er chron­ic lung dis­eases, decreas­es lung func­tion and aggra­vates heart disease.

These mean more emer­gency room vis­its, hos­pi­tal stays and pre­ma­ture death of sen­si­tive peo­ple, includ­ing the very young and very old, accord­ing to the EPA.

But Seneca’s Re said the plant in real­i­ty emits only the tini­est amounts of par­tic­u­late, so lit­tle that it’s near­ly impos­si­ble to mea­sure accu­rate­ly. “It’s like the room I’m sit­ting in, we would be mea­sur­ing a few bits of par­ti­cles in the air,” he said. “If we test­ed it 25 times a year, 24 times it would be OK. The way the rules are, if you’re off that (one) time, you’re off.”

The high­er pol­lu­tion lim­it would give Seneca a “cush­ion or com­fort fac­tor,” Huef­tle said. Seneca’s pro­pos­al would also increase how much of anoth­er pol­lu­tant, car­bon monox­ide, the plant could chug out in an aver­age eight-hour peri­od. The lim­it is 105.8 pounds an hour on an eight-hour average.

In Novem­ber 2011, the plant briefly exceed­ed the lim­it by emit­ting 121 pounds per hour on an eight-hour aver­age. An oper­a­tor was burn­ing wood that was too wet, accord­ing to LRAPA.

The com­pa­ny quick­ly made adjust­ments and pledged bet­ter fuel man­age­ment, reduced out­put of steam and elec­tric­i­ty and instal­la­tion of an alarm to alert oper­a­tors to fuel-mois­ture problems.

Pol­lu­tion in perspective

The pro­posed per­mit would increase the car­bon monox­ide lim­it to 149 pounds an hour on an eight-hour aver­age “to bet­ter reflect actu­al oper­a­tions,” accord­ing to the per­mit appli­ca­tion. “If there was an upset con­di­tion, if we ever ran into some real­ly wet fuel, we could exceed the eight-hour lim­it. We raised that num­ber up. But for the month or for annu­al emis­sion lim­it, it doesn’t increase the total emis­sions that we can put out,” Re said.

All this might sound like a lot of pol­lu­tion. But to keep it in per­spec­tive, the Seneca pow­er plant con­tributes about 1 per­cent of the total “par­tic­u­late mat­ter 10” emit­ted by all indus­tri­al sources in Lane Coun­ty, accord­ing to LRAPA. As a por­tion of all PM10 pol­lu­tion emit­ted in Lane Coun­ty — indus­tri­al, res­i­den­tial and oth­er — Seneca’s emis­sions amount to 0.6 percent.

Still, that’s too much for air activists. “We’re most­ly con­cerned that our air­shed is being com­pro­mised, which means we’re putting an extra bur­den on the lungs of our chil­dren out there in west Eugene,” Arkin said. In the com­ing months, Seneca will face the sig­nif­i­cant tasks required of a ful­ly rec­og­nized major polluter.

Under LRAPA’s pol­lu­tion trad­ing sys­tem, Seneca bought pol­lu­tion cred­its that Inter­na­tion­al Paper in Spring­field wasn’t using because it shut down a machine in the mid-2000s. Re declined to say how much the com­pa­ny paid for the cred­its, but he said the cost was not in the millions.

“They were not pro­hib­i­tive­ly expen­sive,” he said. Seneca was required to buy 17 tons worth of par­tic­u­late cred­its to off­set the 17 tons of par­tic­u­late it’s now ask­ing to emit. That’s a one-to-one off­set. But Seneca chose to buy two off­sets for every one required. Why?

“They had access to them and just want­ed to make very clear that they were off­set­ting the emis­sions suf­fi­cient­ly. (And) it was part­ly a good will ges­ture,” said Can­dice Hatch, Seneca’s con­sult­ing engineer.