Winds of Change Newsletter, March 2010 See sidebar for table of contents
Coal-to-Liquid Plant: Jobs Over Health and Water?
by Dianne Bady
The West Virginia Department of Environmental Protections Division of Air Quality received hundreds of comments on their draft Air Pollution Permit for the proposed TransGas coal-to-liquids plant in Mingo County, which would be the first such plant in the United States.
Most comments went beyond the potential effects of air pollution. The coal industry astro-turf group Friends of Coal organized among people in the hollows adjacent to the proposed site, and many site neighbors, using comments suggested by Friends of Coal, signed several different form letters supporting the plant.
Because of increasing threats and intimidation of mountaintop removal critics, we did not identify the individuals whose comments are excerpted below. People who live closest to the site did not express concerns about air and water pollution, perhaps because they believed the Friends of Coals claim that the plant wont cause environmental problems.
Or, perhaps many people in the poverty-stricken heart of the "trillion-dollar coalfields" are so desperate for any jobs that pollution just isnt an issue.
The Friends of Coal widely circulated a request for public comments in favor of TransGas. A few excerpts:
This project will provide the anchor for the evolution of the regional economy from one of resource extraction into resource transformation This critical first step for Americas energy security and reducing our dependence on imported oil needs to be made in West Virginia, the nations energy state Developers have done an excellent job designing a project that respects and protects the regions environmental assets.
The national Sierra Club submitted a two-inch-thick document with detailed technical comments explaining in what ways the draft permit is faulty. According to the Sierra Club:
TransGas has stated they will use "locally mined" coal which is primarily mountaintop removal coal. Approving the plant will contribute to further destruction of mountains, streams, and communities
The plant will consume more than 3 million tons of coal every year. The Air Divisions designation of the plant as a "minor source" should be reevaluated and all potential emissions included. As a "minor source," TransGas is not required to analyze how its emissions will impact air quality in the region and the public is left in the dark on this important issue. The "minor source" status also exempts TransGas from applying the best available pollution control technology The Division has vastly underestimated the amount of pollution including particulate matter that worsens asthma and other respiratory disease
Topics addressed in other comments included:
Severe problems at the South Africa coal-to-liquid plant: In December 2009, people living near the Sasol coal-to-liquid plant wrote to their government officials: "(We ask) that the government develop an independent intensive health study process in Zamdela investigating the pollution from Sasol and the health of the people"
Extensive water use and contamination: "This plant will use five barrels of water for every barrel of fuel produced. Sixty percent of Mingo residents use well water. What impacts will the plant have on water quality?"
Enormous amounts of poisonous waste produced: "This plant will produce nearly three times as much solid waste by mass than it does useful product approximately 665,760 tons of ash produced each year. Where is this ash going? There does not seem to be much mention of it other than it will be trucked somewhere.
With the impending increased regulation of coal ash by the federal EPA in the wake of the Kingston, TN, disaster, this is a serious issue that needs to be taken into account when considering the overall feasibility of this plant."
Information Gaps: "I have asked the Mingo County Redevelopment Authority and the DEP whether construction and engineering maps have been created and are available for public review. They are not Without access to those kinds of maps, the public cannot adequately comment on the potential impact of the project."
"What are the company and the agency doing to ensure the structural stability of the project site? Structural problems have made large-scale development on mountaintop removal sites hugely expensive. Will the TranGas plant experience the same sinking and settling problems that have plagued the federal prison site in Martin County, KY? What assurance do you have that these problems will not cause the price of the plants construction to rise to $4 billion, $6 billion or even more?"
Wasteful use of coal: Using gasoline produced from coal, "the energy in the outgoing gasoline is equal to about 11% of the energy in the incoming coal." (Note: In a coal power plant about 40 to 45% of the energy is turned into electricity. In both cases, the rest of the energy is turned into heat, which is wasted.)
Greenhouse gas emissions: "Coal-to-liquid produces nearly twice the carbon dioxide as regular gasoline With federal carbon dioxide legislation and EPA regulations looming, who will be investing in this type of fuel?"
Use of taxpayer-funded subsidies: This plant is eligible for state tax credits and other subsidies totaling hundreds of millions of dollars. The state could offer the company (depending on which company estimate of the possible number of jobs we accept as factual) up to $3 million in tax credits per job promised. Surely, with that kind of tax incentive... Mingo County residents could come up with sustainable, long-term jobs that benefit the community rather than another corporate giveaway at the expense of human health."
"The agency might examine this permit in terms of benefits to society versus costs (and honestly examine all usually-hidden costs, such as health care and the value of ecosystem services destroyed by the mountaintop-removal mined coal that would feed this proposed plant)."
The WV Affiliated Construction Trades Foundation comments include detailed technical air assessments by Carpenter Environmental Associates. Among Carpenters conclusions:
Potential emissions of NOx (nitrogen oxides) would exceed that estimated in the permit application Significant new sources of NOx in proximity to (adjacent) Wayne and Cabell Counties may exacerbate a known problem The greater Huntington area historically has exceeded the national and state ambient air quality standard for ozone. (Note: NOx is a major precursor to ozone.)
Further, it is widely anticipated that the current ambient air quality standard for ozone will be deemed inadequate to protect human health. In this event, the standard will be lowered with additional requirements to reduce emissions.
The Carpenter assessment also indicated that TranGas would be a major source of air pollution, not a minor source as stated by the proposed permit.
Carpenter documented that the proposed permit underestimates the emissions of air pollutants including particulates, carbon monoxide and sulfur dioxide, as well as hazardous air pollutants such as mercury and hydrogen cyanide.
Carpenter says that hydrogen sulfide, cancer-causing benzene and other hazardous air pollutants need additional technologies to ensure human safety. These technologies are not included in the proposed permit.