Expansion announcement may have forestalled DEQ investigation

[Editor’s note: This is the first of a multi-part series. The next part will feature Enviva’s response.]

COURTLAND

Letters between Enviva Pellets Southampton LLC officials and the Virginia Department of Environmental Quality — which The Tidewater News obtained in June — indicate that the company’s December 2018 announcement of a planned $75.7 million expansion may have been made with the intention of delaying a DEQ investigation into allegations that the Southampton County wood pellet plant had, for years, been producing toxic emissions in excess of its DEQ air quality permit and a threshold set forth in the federal Clean Air Act.

Enviva Pellets Southampton’s parent company, Enviva Partners LP, is one of the world’s largest producer of wood pellets, also known as solid biomass fuels, which the company sells primarily to European utilities to reduce emissions at coal-fired power plants.

A letter dated June 12, 2018, from Todd Alonzo, manager of the DEQ’s Office of Air Compliance Coordination, addressed to Joe Harrell, manager of corporate environmental health and safety for Enviva Southampton, states that the DEQ “has reason to believe emissions factors in use by Enviva Southampton are not representative of actual operations” and that, “as a result, Enviva Southampton may be incorrectly identified as an area source for hazardous air pollutants (HAPs), and may actually be operating as a major source of HAPs without the appropriate permit.”

According to the federal Environmental Protection Agency website, HAPs, also known as air toxics, are pollutants known or suspected to cause cancer, birth defects and/or seriously impact the environment. According to Tamera Thompson, manager of the DEQ’s Office of Air Permit Programs, a major source is defined in section 112 of the Clean Air Act as a source that has the potential to emit 10 or more tons of a single HAP or 25 or more tons of a combination of HAPs annually. Anything under this threshold, she said, is classified as an area source, which refers to a minor source of pollution.

The letter then states that the DEQ “also has reason to believe that due to the variability of volatile organic compound (VOC) testing results at Enviva Southampton … the VOC emissions factors used by Enviva Southampton may also not be representative of ongoing operations.”

VOCs, according to the EPA, are a group of organic chemicals that include any compound of carbon (excluding carbon dioxide, carbon monoxide and a few other compounds) that, when introduced into the atmosphere, contribute to the formation of ozone. The EPA’s website states that health effects from high-level exposure and/or long-term exposure to VOCs may include damage to the liver, kidney and central nervous system, as well as other symptoms. Some VOCs can also reportedly cause cancer in animals and some are known or suspected to cause cancer in humans.

When asked what the DEQ meant by “emissions factors in use by Enviva,” Thompson explained that Enviva Southampton is required to track its monthly emissions and report the total to the DEQ on an annual basis. Enviva Southampton is also required to keep the monthly records on-site so that they are available if and when DEQ officials conduct their periodic scheduled inspection or a surprise inspection. Wood pellet plants that have not conducted site-specific emissions tests are allowed to use industry standard estimates.

“This industry [biomass wood pellets] as a whole has grown a lot in recent years, especially in the southeast where there are a lot of trees,” Thompson said.

She then explained that the wood pellet industry has relied upon these standard estimates for years. The DEQ, Thompson said, now has reason to believe that site-specific emissions at wood pellet plants, including the Enviva plant in Southampton County, are likely higher than what the industry has traditionally assumed.

The letter concludes with the DEQ requesting that Enviva Southampton test the emissions from its facility, “including those from the burner/dryer, the hammer mills, and the pellet coolers to provide actual site-specific emissions data for VOCs, as well as for the following HAPs: acetaldehyde, acrolein, benzene, cumene, formaldehyde, hydrogen chloride, methanol, methyl isobutyl ketone, phenol, propionaldehyde, toluene, and xylene.”

According to Thompson, these 12 chemicals are the most common ones emitted when wood is dried and turned into biomass pellets.

A pattern of underestimation

Enviva Southampton’s original DEQ air quality permit — which was issued in 2012 prior to the Southampton plant even being constructed, and to which Enviva Southampton initially agreed — specified a facility-wide limit of 3.5 tons per year of any single HAP and allowed no more than 15.2 tons per year in total HAP emissions. VOC limits were set at 99.4 tons per year. These limits, which Thompson confirmed had been negotiated with the DEQ based on industry standard emissions estimates Enviva had provided, placed the then-proposed Southampton facility not only well under the federal major source threshold, but also below the 100-ton-per-year Title V threshold.

Title V, she explained, is a federal operating permit program implemented at the state level, which mandates additional record-keeping, reporting and fees for companies that emit or have the potential to emit over 100 tons per year of any category of pollutant. Companies that meet or exceed the federal major source threshold for HAPs automatically trigger Title V requirements, Thompson added.

Then in May 2013, still several months before the plant began operations, Enviva Southampton actually requested that the DEQ lower the plant’s total HAP limit to 14.7 tons per year, and that its VOC limit be lowered to 79 tons per year. On May 9, 2013, in a letter to Troy Breathwaite of the DEQ, sent along with Enviva Southampton’s revised air quality permit application, Joe Sullivan — an engineer with Trinity Consultants — acknowledges that Enviva’s original plan to process mostly softwood at the Southampton facility could result in higher-than-anticipated VOC emissions. Sullivan further explains that the requested lower HAP and VOC limits are to coincide with the company’s plan to limit production of pellets at the Southampton facility to hardwood only.

The letter from Sullivan states, “As indicated during recent meetings with the Virginia Department of Environmental Quality (DEQ), Enviva has conducted an engineering evaluation at one of its Mississippi facilities to determine whether there are measurable volatile organic compound (VOC) emissions from dried wood hammermills and pellet cooler aspiration systems during production of wood pellets at Enviva’s facilities … Enviva believes that this analysis confirms that there are previously unknown VOC emissions from these sources during production of softwood pellets.”

Further, “In order to ensure that the facility maintains the current minor source [classification], Enviva is submitting this permit application to limit the manufacturing of pellets at Southampton to hardwood only. Enviva believes that this step will reduce potential VOC emissions since VOC emissions from manufacture of hardwood pellets is generally only a small fraction of emissions from softwood production.”

Yet, when Enviva Southampton requested and received another permit revision in 2014, this time presumably after several months of using hardwood exclusively, the VOC limit on which Enviva and the DEQ agreed had nearly doubled to 153.5 tons per year — putting the Southampton plant well above the Title V threshold.

In 2015, when Enviva filed for its third permit revision, the agreed-upon VOC limit rose by another 59.6 percent to its current limit of 245 tons per year.

As for total HAP limits, these were further reduced in 2014, again at Enviva Southampton’s request, to 13.8 tons per year, with limits on individual HAPs being reduced to 3 tons per year. Yet, in its 2015 permit revision request, Enviva Southampton asked that their individual HAP limit be increased to 9.9 tons per year — more than triple the limit the company had requested in 2014, and just under the 10-ton-per-year threshold that would result in the facility being reclassified as a major source of pollution.

Enviva Southampton also requested in their 2015 permit revision application that their limit for total HAPs be raised to 24.1 tons per year, which is an increase of about 74.6 percent over the limit the company had requested in 2014.