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The Ohio Sierra Club hired expert
analyst Alex Sagady of E.
Lansing, MI, to review the permit and plant specifications of Universal Purifying Technology (UPT)’s proposed tire pyrolysis plant. The Club has concerns about emissions from the proposed plant, as well as its proposed location at the old trash-burning power plant site in south Columbus. The site itself is highly contaminated by emissions from the former plant. Also, the permit would allow more air pollution in an area that already has the worst air quality in the city. On Nov. 28 Sagady submitted comments to Ohio EPA on behalf of the Central Ohio Sierra Club. Below is a synopsis of Sagady’s major points.
The proposed UPT facility is unmistakably a chemical manufacturing facility. A chemical manufacturing facility is subject to the 100-Ton Major Stationary Source Threshold emissions requirement. Ohio EPA’s determination that UPT is subject to the 250 ton threshold must be considered to be in error and must be reversed and re-evaluated in favor of a determination that the 100 ton threshold applies. As a chemical manufacturing facility, the plant is also potentially subject to benzene waste regulation. Before a permit is granted, OEPA must determine if the production of nearly 3300 pounds per hour of pyrolysis oil from tires containing benzene and other chemical compounds will trigger further regulatory requirements.
Operation of a pyrolysis reactor and associated equipment has the potential to lead to overpressure events. The application shows no details on exit points and disposition of relief gases from pressure-operated relief valves. Given the hazards such material releases would pose to workers in the facility, it is likely that emission products would be conveyed to outdoor vents. The UPT application should not be approved until and unless more details are disclosed about the entire matter of handling valve-venting emissions. UPT should be placed under a burden of showing how pressure operated relief valves, flame arrestors and filters will be cleaned and maintained to avoid flow obstruction events.
The sulfur dioxide emission characterization does not account for worst case conditions admitted by the applicant at their Korean unit. UPT is unlikely to be able to comply with the carbon monoxide (CO) emissions of the permit as issued without “cherrypicking” the operating conditions of the plant during the required stack test. Therefore, it should be subject to continuous CO emission monitoring and emission limitations. If unmonitored operations begin, UPT will be able to evade accountability for compliance with CO emission limitations.
UPT’s characterization of plant-wide fugitive emissions is incomplete. There can be no assurance that fugitive emissions will remain as low as those indicated in UPT’s submittal without a permit requirement grounded in Ohio Best Available Technology provisions for at least a minimal leak detection and repair program.
The permit should not allow release of uncombusted synthesis gas during shutdown scenarios.
The scrubber, metal washing operations and the oil water separator have the potential to contaminate wastewater with toxic metals, polycyclic aromatic hydrocarbons and certain other hydrocarbon compounds. There does not appear to be a plan for pre-treatment of any of this wastewater before discharge to public sewers. This issue must be clarified with City of Columbus wastewater authorities and pre-treatment requirement enforcement staff.
All of the emission calculations in UPT’s submittal are based on a 330-day year. If UPT is not bound by a federally enforceable permit provision limiting days of operation per year to 330, then OEPA should insist on emission calculations based on a full 365-day year.
The City of Columbus Health Department also made comments on the UPT permit. They conclude, “It will be the lack of information and absence of comparable models that will continue to obscure the assessment of any potential impacts presented by this process. It is our current position that to directly address any public health concerns regarding this process, more specific data is required.” They requested that Ohio EPA provide assistance and information in addressing these issues.
The proposed UPT facility is unmistakably a chemical manufacturing facility. A chemical manufacturing facility is subject to the 100-Ton Major Stationary Source Threshold emissions requirement. Ohio EPA’s determination that UPT is subject to the 250 ton threshold must be considered to be in error and must be reversed and re-evaluated in favor of a determination that the 100 ton threshold applies. As a chemical manufacturing facility, the plant is also potentially subject to benzene waste regulation. Before a permit is granted, OEPA must determine if the production of nearly 3300 pounds per hour of pyrolysis oil from tires containing benzene and other chemical compounds will trigger further regulatory requirements.
Operation of a pyrolysis reactor and associated equipment has the potential to lead to overpressure events. The application shows no details on exit points and disposition of relief gases from pressure-operated relief valves. Given the hazards such material releases would pose to workers in the facility, it is likely that emission products would be conveyed to outdoor vents. The UPT application should not be approved until and unless more details are disclosed about the entire matter of handling valve-venting emissions. UPT should be placed under a burden of showing how pressure operated relief valves, flame arrestors and filters will be cleaned and maintained to avoid flow obstruction events.
The sulfur dioxide emission characterization does not account for worst case conditions admitted by the applicant at their Korean unit. UPT is unlikely to be able to comply with the carbon monoxide (CO) emissions of the permit as issued without “cherrypicking” the operating conditions of the plant during the required stack test. Therefore, it should be subject to continuous CO emission monitoring and emission limitations. If unmonitored operations begin, UPT will be able to evade accountability for compliance with CO emission limitations.
UPT’s characterization of plant-wide fugitive emissions is incomplete. There can be no assurance that fugitive emissions will remain as low as those indicated in UPT’s submittal without a permit requirement grounded in Ohio Best Available Technology provisions for at least a minimal leak detection and repair program.
The permit should not allow release of uncombusted synthesis gas during shutdown scenarios.
The scrubber, metal washing operations and the oil water separator have the potential to contaminate wastewater with toxic metals, polycyclic aromatic hydrocarbons and certain other hydrocarbon compounds. There does not appear to be a plan for pre-treatment of any of this wastewater before discharge to public sewers. This issue must be clarified with City of Columbus wastewater authorities and pre-treatment requirement enforcement staff.
All of the emission calculations in UPT’s submittal are based on a 330-day year. If UPT is not bound by a federally enforceable permit provision limiting days of operation per year to 330, then OEPA should insist on emission calculations based on a full 365-day year.
The City of Columbus Health Department also made comments on the UPT permit. They conclude, “It will be the lack of information and absence of comparable models that will continue to obscure the assessment of any potential impacts presented by this process. It is our current position that to directly address any public health concerns regarding this process, more specific data is required.” They requested that Ohio EPA provide assistance and information in addressing these issues.