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  • June 3, 2021

Jefferson County Foundation thanks West Virginians for Sustainable Development (WVSD) for its successful pursuit of a complaint against Rockwool in its home country of Denmark. The Foundation has long recognized that Rockwool failed to properly engage the public in a transparent and responsive way and failed to do appropriate environmental due diligence. We are very pleased to see that, after a long investigation under OECD guidelines, the Danish agency has concluded the same. The Foundation is currently pursuing several key projects aimed at protecting the community and our natural resources from the effects of Rockwool’s failure to perform appropriate due diligence when the company chose to site its factory in a vulnerable area: challenges of Rockwool’s stormwater permits, facilitating a water monitoring program, and challenging Rockwool’s air permit. Through our work on zoning and the JCDA the Foundation is also working to ensure that, as we move forward, our region is smarter about who and how we invite development. Please join us in thanking the WVSD for their hard work and help us redouble our efforts to hold Rockwool accountable to operate safely while we promote sustainability and protection of our health, heritage, and environment in the Eastern Panhandle.

Read more here.

Read more about what Rockwool could do to voluntarily update their air permit and get an individual NPDES permit.

  • August 10, 2020

Jefferson County Foundation has put together a tutorial to further help clear up confusion about Rockwool’s recent announcement about changing their fuel source. Does that mean they are no longer using coal at all? Watch the video to find out (see below, or watch it here on our Youtube Channel).

Click here to view and download the letter from Rockwool to the WVDEP from March 2, 2020

Click here to view and download the letter from the WVDEP to Rockwool from March 11, 2020

Click here to view the letter Jefferson County Foundation sent the WVDEP and the EPA on July 29, 2020.

Click here to view and download the letter from the WVDEP to the Foundation from August 5, 2020

Recent News

Rockwool Changing Fuel Source – Needs New Air Permit [more]

Fact Checking Rockwool’s Statement on Natural Gas News [more]

  • July 31, 2020

Rockwool recently posted on their Rockwool Ranson Community Facebook page that they are “planning to start operations using natural gas instead of coal.” It’s interesting that they are only now talking about this since they notified the West Virginia Department of Environmental Protection in March of 2020. It has been 143 days. Why the long wait? Maybe it’s because Jefferson County Foundation wrote the DEP and the EPA on Wednesday, July 29 telling them that Rockwool needs to redo their air permit because of their change in operating parameters. Rockwool wants to have a shiny object to distract us from there are major issues here that need to be addressed. 

Issues

  1. Rockwool and the DEP need to entirely re-do the BACT analysis with natural gas as the sole fuel source for the Melting Furnace.
  2. At minimum a Class II administrative change with public notice needs to be made for this modification or more appropriately an entirely new air permit.
  3. 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.

What Rockwool Said and What are the Concerns

In their statement from July 31, 2020, Rockwool states:

“That’s right – we’re planning to start up factory operations using natural gas instead of coal.

Converting from coal to natural gas for the melting furnace will significantly reduce the environmental impact of our operations – that’s great for Jefferson County and beyond.” 

It is critical to note that Rockwool was planning to use coal not only to fuel the Melting Furnace, but as a raw material, also known as an in-process fuel. The Melting Furnace was meant to be powered by four oxy-fuel burners (natural gas) creating 23% of the energy and five coal burners (burning crushed powered coal) creating 77% of the energy (as measured by MW).1 But they were also using coal as raw material in the actual melting furnace.2 It seems they now plan that they intend to replace these five coal burners with oxy-fuel burners. Are they saying, they plan to use no coal in any process as raw material or fuel of any type – 100% no coal?

There is no way to know for sure, either from their letter or this statement. 

The press needs to push: Is Rockwool 100% stopping the use of coal completely in all processes and all capacities? Or, will Rockwool continue to use coal in some capacity, just not to fuel those five burners for the Melting Furnace?

Rockwool states:

“We expect CO2 emissions from the melting furnace to decline by around 30 percent along with reductions in other emissions as well.”

What they don’t say is that the Carbon Monoxide (CO), a regulated emission in its own right, will increase significantly.3 And, what is more important is do they plan to appropriately abate with the Best Available Control Technology, which will actually produce more CO2?  

The answer to this is unknown, because the DEP inappropriately accepted this as a Class I administrative change, instead of the Class II administrative change with public notice, this increase in regulated emission legally qualifies for. Rockwool needs to be required to redo the Best Available Control Technology (BACT) for the Melting Furnace. They need to choose BACT that is appropriate for this new emissions profile and have the EPA review it. Therefore, it would be best if they applied for an entirely new permit. 

“Converting to natural gas also means less heavy truck traffic, as we will not need any coal deliveries – another win for Jefferson County and the environment.”

We agree! Thank you!

“And in case you’re wondering, Mountaineer Gas will supply the gas via the existing pipeline infrastructure, which is already completed and well-functioning. This conversion will not require natural gas truck deliveries to the factory.”

Wow, really interesting that they waited until the day after the FERC public comment was closed to say this!

Columbia Gas has recently applied for an extension of their Certificate of Public Convenience and Necessity (CPCN) for the Potomac Pipeline. This is a pipeline that will carry fracked gas from Pennsylvania to the Mountaineer Gas line in the Eastern Panhandle gas line extension, which will carry gas to Rockwool. The project was originally permitted in 2018 but was not constructed due to a legal battle with the state of Maryland. This pipeline will cross 19 streams, 10 wetlands, and the Potomac River, which supplies water to over 6 million people downstream of that point. Columbia Gas has always argued that the gas is needed in Jefferson County, i.e. by Rockwool. The Federal Energy Regulatory Committee (FERC) was accepting public comment until July 30 on the extension of the CPCN for the pipeline. If Rockwool had announced this information before the deadline, many of us would have used this information to argue that the gas line does not fulfill a public necessity. 

Temporal coincidence? 

“That we’re able to convert to natural gas is a result of the highly advanced, proprietary, fuel-flexible melting technology that we’re deploying here. To our knowledge, no one else in our industry has this capability.”

Rockwool is a very old product that has been replaced by products that do not require such environmentally unfriendly practices to make. Many will remember there was once a Rockwool plan there in Jefferson County but it went out of business before most of us were born. So, saying you are doing better than a dying breed is not saying much. 

Also, if this is first of its kind technology, then the air permit is completely wrong! The air permit was based on the emissions “proportionally scaled down” from the Byhalia, Mississippi plant. Now we are to understand that the Byhalia plant does not even have the same type of furnace? This means the air permit must be completely redone. 

“The air permit authorizing our operations allows for using both fuel sources – and it has always been part of the plan to eventually convert to natural gas for the melting process. We’re extremely pleased that we’re able to start up on gas, thus reaping the environmental benefits of doing so straight away.”

Actually, in the air permit application, Rockwool said that using only natural gas in the Melting Furnace was “technologically infeasible.” According to the Rockwool permit application: the use of only natural gas as a fuel would “fundamentally redefine the process of a coal/natural gas/oxy-fired Melting Furnace.” And in Rockwool’s BACT analysis for CO2e (greenhouse gases) from the Melting Furnace, natural gas as a fuel source instead of coal was specifically excluded, because it was said to be “technically infeasible.” 

This means the DEP and Rockwool independently need to redo the BACT analysis for the Melting Furnace considering natural gas as the only fuel sources for the Melting Furnace. Now that Rockwool has admitted they can afford to use natural gas as the sole fuel source in the Melting Furnace and that it is technically feasible to do so. Rockwool should therefore be required to use only natural gas as a fuel source as it is the best available technology for containment of CO2e, and should not be allowed to revert to coal if and when they so choose.  

Further, Rockwool’s BACT analysis of NOx for the Melting Furnace, because coal instead of natural gas was being utilized, Low-NOx and Ultra Low-NOx natural gas burners were not considered as a technically feasible option for BACT of NOx for that emissions source. Rockwool needs to be required to use them now. 

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. And certainly, should not be celebrated as some sort of altruistic sacrifice!

Click here to see a video tutorial on Rockwool’s Change in Operating Parameters

1 Rockwool application to Office of the State Fire Marshall for Varience, 4/10/18

2 Information presented at Rockwool Open House in 2018

3 Based on AP-42 – EPA Compelation of Air Emmision Factors and Process Information Standard Reference

  • July 30, 2020

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

Rockwool is changing their fuel source
Rockwool needs to provide more information
DEP needs to be more transparent
DEP and Rockwool need to redo the BACT analysis
ROCKWOOL NEEDS TO APPLY FOR A NEW AIR PERMIT!

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.

  1. Rockwool and the DEP need to entirely re-do the BACT analysis with natural gas as the sole fuel source for the Melting Furnace.
  2. At minimum a Class II administrative change with public notice needs to be made for this modification.
  3. 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.

Click here to view the letter Jefferson County Foundation sent the WVDEP and the EPA on July 29, 2020.

1. BACT Analysis Needs To Be Redone

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 FurnaceTons Per Year From Melt FurnaceTotal Tons Per Year Produced by the Plant
NOx67%163.37274.31
SOx100%147.31147.31
Acid gas (H2SO4)100%16.3716.37
Greenhouse Gas CO2e62%95,547152,933
PM1023%36.01155.59

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.

Click here to see a video tutorial on Rockwool’s Change in Operating Parameters

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.