The Sierra Club, in particular, wants the DEP to withdraw its draft air quality permit and send the developer, Domestic Synthetic Fuels, back to the drawing board to produce what it believes would be more accurate emissions data.
Jim Kotcon, Sierra Club West Virginia Chapter conservation chair, broadly outlined the club’s objections at a recent public hearing DEP held on the permit in Mason County.
There are a large number of areas where DSF is underestimating emissions in its permit application, Kotcon said. And DEP offered an uncritical review of the data.
Sierra Club detailed its concerns in a 34-page letter submitted to DEP as part of the public comment period.
Asked about the objections, DEP said in an email exchange, “Mr. Kotcon attended the public meeting we held … and his comments and concerns were given on the record. All comments submitted to the WVDEP’s Division of Air Quality regarding DSF’s proposed facility are currently being reviewed and will be taken into consideration before a final determination is made. The comments received will be addressed in our response to comments document, which will be available to the public upon completion.”
DSF plans to build the plant on a 200-acre industrial site north of Point Pleasant along the Ohio River.
DSF says its plant will employ direct coal-to-liquids technology to convert coal and natural gas, using heat and pressure, into low-sulfur diesel and jet fuel, gasoline and other by-products. It will use about 23 million cubic feet of natural gas and 2,500 tons of coal per day to produce 451,500 gallons of fuel.
Once built, DSF projects the plant will employ 130 people, and generate 130 new Kanawha County mining jobs. The $1.2 billion investment will gross $300 million per year and generate $11.5 million per year in annual payroll and benefits.
DSF says that this will be the first full-size direct coal-to-liquids plant in the nation. Small-scale projects have succeeded in the U.S., and similar full-size plant has been operating in China since 2008.
DSF says previous coal-to-liquids plants have been environmentally dirty, using an indirect method of burning coal to create gases processed into liquids. The Mason County plant will be near-zero emissions and will self-recycle, preventing new burdens to landfills.
Supporters include the West Virginia Coal Association, the West Virginian Oil and Natural Gas Association, the Independent Oil and Gas Association of West Virginia, the Business and Industry Council, assorted trade unions and a bevy of public officials.
DEP approved the draft permit in June. Pending final approval, DSF expects to begin building in October and to open the plant in late 2022 or early 2023.
Opposition to the plant comes from a variety of individuals, the Ohio Valley Environmental Coalition and the Sierra Club, among others.
Sierra Club alleges in its letter that DSF’s permit application includes “critical and profound flaws.” The plant, it says, “would spew toxic chemicals on its neighbors in an area that is already burdened with the adverse health impacts of living across the river from two mammoth coal plants. … Accordingly, this permit must be stopped in its tracks.”
DSF wrongly states that Mason County is considered in attainment of state and federal air quality standards, Kotcon said at the meeting. In fact, there are no air quality monitoring stations in the county. “Absence of evidence is not the same as evidence of absence.”
Part of Sierra’s argument hinges on the difference between a major and minor stationary pollution source. A major source directly emits or has the potential to emit at least 100 tons per year (TPY) of any air pollutant subject to regulation.
But DEP has approved the plant as a minor pollutant source, which has a lower regulatory threshold for health and environmental effects and less stringent emissions standards.
In the draft permit, DEP authorized these potential increases in emissions: will be authorized by this permit action: carbon monoxide, 71.32 TPY, oxides of nitrogen, 80.91 TPY, particulate matter less than 2.5 microns, 54.66 TPY; particulate matter less than 10 microns, 78.12 TPY; particulate matter, 83.49 TPY; sulfur dioxide, 27.19 TPY; volatile organic compounds, 86.10 TPY; total hazardous air pollutants, 16.96 TPY.
“By avoiding major source classification for hazardous air pollutants,” Sierra says, DSF dodges its legal duty to utilize the most stringent control technology available.”
Sierra and OVEC both note the plant’s proximity to the town itself, along with two schools. They argue that DEP’s draft permit fails to take into account not only DSF’s flawed projections but the cumulative effects of DSF plus the two nearby power plants.
Sierra wants DEP to withdraw the draft permit and require DSF to submit a new one that accurately estimates emissions, complies with major source regulations and includes sufficient data to support its emissions estimates. The application should provide for ambient air monitoring, a health risk assessment, consideration of odors and nuisance impacts, and an assessment of greenhouse gas emissions.