Jefferson County Foundation is calling on the West Virginia Department of Environmental Protection Division of Air Quality (WVDEP) and the federal Environmental Protection Agency (EPA) to have Rockwool redo its air permit due to a change in fuel source. It has come to light that Rockwool notified the WVDEP in March of 2020 that it plans to operate its Melting Furnace using only natural gas.
Background
In a March 2, 2020 letter (click to view) to the West Virginia Department of Environmental Protection (DEP), Rockwool made the DEP Department of Air Quality (DAQ) aware that they were changing their fuel source for the Melting Furnace and will now use natural gas as the sole fuel source.
We are encouraged that Rockwool maybe using less coal in their process. However, there are some really important things to note with this change and there are major issues that must be addressed to ensure the air of our region is protected as much as it could be.
Though Rockwool will stop using coal as fuel in the Melting Furnace, they will still be using coal as a raw material or an in-process fuel. Why don’t we know for sure how much coal? Because the DEP DAQ did not follow up and require that Rockwool define this change further. The DEP reply letter states:
“The Division of Air Quality confirms that on March 4, 2020, we received your letter that provided information on Roxul’s plans to operate the Melt Furnace using only natural gas and without the use of coal. Please note that all applicable conditions in the permit remain in effect.
Should you have any questions, please Mr. Joe Kessler at (304) 414-1271.”
Key Points
That’s it. That’s the letter. You can view the letter from the WVDEP here.
These two letters were posted in a location on the DEP website with a small, seemingly random collection of communications, including only four postings since the final approval of the construction air permit in April of 2018. The DEP didn’t publish these letters on the website until sometime after May 20, 2020.
The issues
While we are encouraged that Rockwool maybe using less coal, this situation creates or highlights three issues that must be addressed by the DEP DAQ urgently.
- Rockwool and the DEP need to entirely re-do the BACT analysis with natural gas as the sole fuel source for the Melting Furnace.
- At minimum a Class II administrative change with public notice needs to be made for this modification.
- The DEP and Rockwool need to be transparent about this process including providing all the redacted information from the permit application to the public so the public may adequately evaluate the emission limits and BACT.
These issues need to be immediately addressed by the DEP DAQ.
1. BACT Analysis Needs To Be Redone
What is BACT?
BACT stands for Best Available Control Technology. It is required on major new or modified stationary sources of air pollution in clean areas (i.e., attainment areas). Jefferson County is an attainment area. Rockwool is a major stationary source of air pollution. They had to conduct a BACT Analysis and present it with their Prevention of Significant Deterioration (PSD) Air Permit Application to DEP. DEP was supposed to do their own version and then compare it with what the company said they though the BACT should be. DEP did not do their part; instead, they took Rockwool’s word.
A BACT Analysis is called a “top-down” evaluation, meaning that one starts with the best controlling technology or mode of operation, including type of fuel. Top-down BACT consists of the following 5 step process:
- Step 1 – Identify all control technologies
- Step 2 – Eliminate technically infeasible options
- Step 3 – Rank remaining control technologies by control effectiveness
- Step 4 – Evaluate most effective controls and document results
- Step 5 – Select BACT
General Requirements
A. Best Available Control Technology (BACT) means an emission limitation (including opacity limits) based on the maximum degree of reduction which is achievable for each pollutant, taking into account energy, environmental, and economic impacts, and other costs.
B. The analysis must be pollutant and emission unit specific with respect to each pollutant subject to a BACT review.
C. Evaluate entire range of demonstrated options, including alternatives that may be transferable or innovative.
D. The level of detail in the control options analysis should vary with the relative magnitude of the emissions reduction achievable.
E. Emission limits should be expressed in pounds/hour (based on maximum capacity) and in terms of process unit variables such as material processed, fuel consumed or pollutant concentrations (e.g., lbs/MMBtu, lbs/gal of solids, g/dscm).
F. Emission limits and work practice standards must be enforceable. Permit conditions should specify appropriate stack testing, continuous emission monitoring, continuous process monitors, recordkeeping, etc.
Impact Analysis
Here are some examples of where energy, economic, or additional environmental impact can be factored in, resulting in a high-ranking, technologically feasible BACT to be excluded.
- Energy
Natural gas for operating an afterburner is not available based on local regulations. - Economic
- The increased cost of the final product (e.g., automobile, cement, coke, etc.) would increase to a level so that the entire project would no longer be feasible.
- The increased cost is way out of proportion to the environmental benefit. (e.g., the increased cost of going from 93% to 94% control increases the capital cost from $2,000,000 to $4,000,000 and the operating costs from $500,000/year to $1,000,000/year but reduces the emissions of nitrogen oxides by only 50 tons per year.)
- Environmental
A wet scrubber may create a by-product which cannot be disposed of without creating a more detrimental impact.
In the original BACT analysis for the Melting Furnace, Rockwool claimed that using natural gas as a sole fuel source was “technically infeasible.” Specifically, because Rockwool claimed this, they were allowed to used coal, despite the fact that this has higher emissions of CO2e, and SO2. Now that Rockwool is admitting that using natural gas as the sole fuel source for the Melting Furnace is technically feasible and affordable, they must be REQUIRED to do this as it is the best available technology to reduce emissions.
Because Rockwool was not considering using natural gas as the fuel source for the Melting Furnace, they did not consider the best available technology for controlling emissions from the natural gas burners. This must now be done to further limit emissions. For example, the best available technology to limit NOx from natural gas burners is the use of Low or Ultra Low-NOx burners. This was not considered by Rockwool or required of them because, again, this was not considered a technically feasible fuel source.
Natural gas burners actually produce more carbon monoxide than does coal combustion. Therefore, this must be evaluated to ensure the best available technology is being used to maximally control the emissions of carbon monoxide. In this case, oxygen is being used and may be required at a higher rate to account for the increased CO emission.
By having first applied for an air permit and claiming it was technically necessary to operate with coal-burning technology, then at a later date substituting that with natural gas-only technology, Rockwool has avoided appropriate BACT analysis. In doing so, Rockwool achieved being permitted for far more emissions than are necessary for their process, and afforded themselves built-in leniency for their emissions. This kind of deception and disregard for our air quality cannot be tolerated. Further, it is clear that one cannot rely on the Title V permit (operational air permit) process to provide a backstop protection for these insufficiencies, as Rockwool has been operating in Byhalia for over five years and has yet to obtain a Title V permit.
The BACT analysis must be redone in light of this new information, that natural gas is now technically feasible for use in the Melting Furnace, so that Rockwool is required to use the truly best available technology and incorporate more appropriate emission limits into the permit.
How much does the Melt Furnace contribute to the emission of the plant at Rockwool Ranson?
We know from the Fire Marshall that 77% of the power for the Melting Furnace was being provided by coal and 23% was being provided by natural gas. This is a change of 77% in the highest emission source for most emissions.
| Emission (pollutant) | % of total emissions from Melting Furnace | Tons Per Year From Melt Furnace | Total Tons Per Year Produced by the Plant |
|---|---|---|---|
| NOx | 67% | 163.37 | 274.31 |
| SOx | 100% | 147.31 | 147.31 |
| Acid gas (H2SO4) | 100% | 16.37 | 16.37 |
| Greenhouse Gas CO2e | 62% | 95,547 | 152,933 |
| PM10 | 23% | 36.01 | 155.59 |
This fuel change represents a 77% change in the emissions source that creates 70% of the plant’s overall emissions.
2. Rockwool needs a new air permit!
At very least, this needs to be considered a Class II administrative change with public notice. 45 C.S.R. 13-4(2)(b), requires that a “Change in a permit condition as necessary to allow changes in operating parameters, emission points, control equipment or any other aspect of a source which results in an increase in the emission of any existing regulated air pollutant or any new regulated air pollutant; or” requires a Class II modification. This description is met by this change and, therefore, a Class II administrative change with public notice should be conducted.
This will require a change in operating parameter, as the Melting Furnace will now be using only natural gas as a fuel. While Rockwool says that this was previously approved, in the publicly facing documents of the air permit there was no specific approval of natural gas for use in the Melting Furnace. If there in fact was approval of this, then several other required steps were omitted (as outlined in the letter).
As already discussed, the control equipment will need to be changed based on a new BACT analysis. This is critical to keep air emissions as low as possible.
This change in fuel source will result in an increase in emission of CO (carbon monoxide)[1]. CO is an existing regulated air pollutant.
Because this change in operating parameter will require a changing control equipment and result in an increase in emission of a regulated air pollutant, a Class II administrative change with public notice is required. This was not done and it must be corrected. Due to the BACT needing to be redone as noted previously, EPA review is required and, because a majority of the emissions come from this source (Melting Furnace), it would be most appropriate to require Rockwool to do an entirely new permit.
[1] According to AP-42 – EPA Compilation of Air Emission factors and process information standard reference for air permitting since 1972. https://www3.epa.gov/ttn/chief/ap42/ch01/
3. Transparency and Due Diligence
The original permit
The Clean Air Act and state regulation prohibit redaction of any information that meets a broad definition of “emissions data.” Rockwool and the DEP obfuscated this requirement by including much of this information by citation only. This information was cited in the PSD application where much of the information was redacted from public view. This information must be provided to the public so the public can property evaluate the BACT and emissions limits.
Notifying the Public of this change
It is not clear why this recent and important communication was posted in a seldom viewed location with seemingly random communications or how the public would have known that this is the location they should have been watching for such information.
Rockwool must provide more information about this change
The DEP’s response letter seems intentionally vague and invites further non-written communication. This overtly limits public awareness of the process and implications of such actions. The DEP handling of this thus far perpetuates the lack of transparency and lack of due diligence that has plagued the agency’s handling of the Rockwool project from the start.
What Needs to Happen
We ask that a Class II administrative change with public notice be conducted or Rockwool be required to seek an entirely new air permit, that the BACT analysis be repeated by both Rockwool and the DEP independently, that EPA be advised of these significant permit changes, and that the process be conducted in an open and transparent way including making all cited redacted material available to the public.