In a letter to the Idaho Department of Environmental Quality (IDEQ), an Environmental Protection Agency (EPA) official outlines five concerns EPA has regarding Southeast Idaho Energy’s draft permit to construct a coal gasification fertilizer plant near American Falls in Southeast Idaho.
The Nov. 18 letter from Richard Albright, EPA air, waste and toxics director in Seattle, to Martin Bauer, IDEQ’s air quality division manager in Boise, addresses the proposed plant’s new source performance standards, potential to emit, Best Available Control Technology (BACT), mercury, and slag. Albright noted IDEQ and EPA Region 10 staffers have discussed the $1 billion project.
“The EPA’s comments are being addressed along with public comments submitted during the comment period. Typically, the permit will be revised as needed in response to all comments, and a response to comments will be issued with the final permit,” said Cheryl Robinson, IDEQ air quality engineer/modeling analyst in Boise.
“When all comments have been addressed and any needed changes have been made to the permit, DEQ will make a determination whether the changes are significant enough to schedule a second public comment period. If another public comment period is not needed, DEQ will issue the final permit accompanied by a Response to Comments document,” Robinson said. IDEQ expects to make a decision in early 2009.
Southeast Idaho Energy (SIE) spokesman John Burk said his company’s project is environmentally, financially, and technically sound. SIE, a subsidiary of Refined Energy Holdings of New York, still hopes to break ground in late 2009.
SIE proposes to use a Selexol unit to remove hydrogen sulfide from its synthetic gas stream, strip the H2S from the Selexol solvent, and send it to the sulfuric acid production unit. In its letter, EPA says SIE’s sulfuric acid production unit contemplated for the project cannot be considered a control unit and should be required to comply with sulfuric acid plant performance standards.
While it appears the plant’s nitrogen oxide and particulate emissions will be marginally below federal thresholds, EPA recommends that IDEQ require SIE to perform a detailed analysis or provide adequate monitoring, record keeping, and reporting to ensure those air pollutants stay within regulations.
Albright wrote it appears IDEQ relied entirely on SIE’s analysis for Best Available Control Technology for the project, failing to adhere to EPA’s five-step, top-down process. “In addition, it appears that the cost effectiveness analysis may have been performed incorrectly,” the letter stated, recommending that IDEQ rigorously ensure accurate BACT determinations and correct those that need to be updated.
EPA also stated it is concerned the magnitude or impact of new mercury emissions from the plant to the surrounding area has not been sufficiently addressed. It noted fish tissue samples taken from the American Falls Reservoir and Portneuf River show elevated levels of mercury contamination. A Michaud Flats Superfund site has been designated east of American Falls and west of Pocatello, where the J.R. Simplot Co. and FMC Corp. have operated phosphate processing plants.
Albright pointed out that EPA has initiated a region-wide mercury strategy to address unregulated atmospheric sources. It plans to work with states, tribes, and individual companies to develop voluntary agreements to reduce mercury emissions through pollution prevention and waste partnerships.
EPA also recommended that the SIE plant’s coal feedstock and slag be analyzed for potential problem contaminants before SIE develops market plans to sell slag as a byproduct for roads or landfill disposal.
Gasifying an expected 2,000 st of coal daily, the plant would produce anhydrous ammonia, granular urea, UAN, and sulfuric acid. An estimated 1,000 construction workers would be employed on the project. When the plant is running, about 150 full-time employees would work there.