[Editor’s note: This is the second of a multi-part series. The third part will address the possibility that Enviva’s $75.7M expansion was prompted and/or accelerated by the DEQ’s June 2018 letter.]

COURTLAND

In response to the DEQ’s June 2018, letter, Royal Smith, executive vice president of operations for Enviva Southampton, wrote to Michael Dowd, director of the DEQ’s Air and Renewable Energy Division, on July 12, 2018, stating that the June 12 letter set forth “a schedule for submitting a test protocol, and performing emissions testing, that is impossible for Enviva to meet.”

Smith then stated, “Most importantly, as discussed with Mr. [DEQ Director David] Paylor and other DEQ representatives on July 2, [2018] Enviva has immediate plans to expand the Facility and install significant new emission controls, including a regenerative thermal oxidizer (‘RTO’), on the existing dryer. These plans pre-date the receipt of the June 12th letter, and will result in very significant reductions in total VOC and HAP emissions from the Facility … Rather than conducting emissions testing on the Facility in response to the June 12th letter, when the facility is in the process of engineering major operational changes and reductions in VOC and HAP emissions, Enviva requests that DEQ delay the emissions testing requirement until Enviva implements proposed modifications to the Facility as discussed in this letter.”

According to Ann Regn, a spokeswoman for the DEQ, an RTO is a piece of equipment used to control air pollution that works similar to an incinerator in that it uses temperatures in excess of 1400 F to decompose HAPs and VOCs in exhaust air, as well as other airborne pollutants, into carbon dioxide and water vapor.

Tamera Thompson, manager of the DEQ’s Office of Air Permit Programs, confirmed that Enviva Southampton’s response to the DEQ’s June 12, 2018, letter, both in writing and in person during the company’s meeting with Paylor, had not refuted the DEQ’s claims that the Southampton plant may be over-polluting, nor produced any evidence to suggest that Enviva Southampton was still operating within the HAP and VOC limits in its air quality permit or within the federal threshold for area sources.

“They asked us to delay the requirement to test, specifically all the HAP testing, until after the expansion, with the additional controls, was complete,” Thompson said.

On Aug. 1, 2018, Dowd replied to Enviva Southampton’s July 2018 letter, granting the Southampton County plant’s requested suspension of the DEQ’s June 12 letter. This was done on the condition that Enviva Southampton’s permit application to the DEQ for the proposed expansion specifies how the company plans to control HAP and VOC emissions, and that the company conducts emission testing on the modified facility once the expansion is complete. Dowd’s response also mandates a deadline of Sept. 30, 2018, for Enviva Southampton to submit the permit application, which Thompson confirmed the company did indeed meet.

Maria Moreno, a spokeswoman for Enviva Partners LP, however, claimed on Friday, July 12, that Enviva’s Southampton plant has been operating in compliance with all terms in the plant’s 2015 air quality permit, to include stack testing for air emissions. Stack testing, Thompson confirmed, is another term for emissions testing. Moreno then told The Tidewater News that the Enviva Southampton plant’s most recent stack compliance report, based on stack testing conducted in April 2019, indicated the plant to be in full compliance with its current air quality permit. This report, she said, was submitted to the DEQ.

Yana Kravtsova — Enviva Partners’ vice president of environmental affairs and chief compliance officer — likewise referenced the April 2019 test results on Thursday, July 24, when responding to the allegations made in the first part of this series, which was published in the Wednesday, July 23 edition of The Tidewater News. Kravtsova added that the Southampton facility has “never received a notice of violation for the facility.”

Thompson, when asked about the April 2019 test results, clarified that the testing Enviva conducted this year had only been for particulate matter and nitrogen oxides, and had not included any results for HAPs or VOCs. As such, these results are “not the same as requested by DEQ in June 2018,” she said.

“With regard to HAP emissions,” Kravtsova said, “These are not required to be tested per the terms of the existing permit. However, Enviva has no reason to believe we have ever exceeded any HAP emissions limitations in our SOU permit.”

The vice president then claimed that Enviva’s purpose in informing the DEQ of its expansion plans last summer and committing to install additional air emission controls at the Southampton plant was to “account for the expansion and transition to a higher softwood pellet production.”

“One change we are making across our entire operation is to use a higher percentage of softwood versus hardwood,” she said. “[Softwood] happens to be more energy dense and efficient, which is a win for the environment, and for our customers.”

Kravtsova explained, “The wood pellets the Southampton plant produces are used as a drop-in substitute for coal by utilities around the world. Wood pellets have been found to reduce lifecycle greenhouse gas emissions by roughly 85 percent and reduce the levels of sulfur, lead, arsenic and mercury that coal plants would otherwise have emitted to the atmosphere … By providing power companies with sustainably-produced wood pellets, we allow them to quickly transition away from coal with minimal changes to their infrastructure. And because utilities can do so quickly and very cost effectively, demand for our product is growing rapidly, and our facilities are growing and changing to meet this demand.”

However, when asked if it would be accurate to say Enviva’s position is that, were the Southampton plant not expanding and/or transitioning to softwood, additional emission controls at the facility would not be needed, Kravtsova did not answer “yes” or “no.” Instead, she issued the following statement:

“To be clear, we have demonstrated compliance with Southampton’s existing air permit consistently throughout its operation, most recently with its compliance stack testing in April. We are confident that the proposed emissions controls associated with the transition to softwood and expansion of the facility will be similarly fully compliant with the plant’s operating profile following their installation.”

Thompson, however, said that the DEQ’s purpose in requiring testing last summer was to determine “if there was/is a problem.” She added, “Had they not come and proposed the expansion, we would have wanted them to do the testing [originally requested].”

Regarding the allegations in the Wednesday, July 23 article concerning a “pattern of underestimation,” Kravtsova acknowledged that Enviva has made changes periodically to the emissions estimates for its wood pellet plants, in order to “reflect adjustments in our plant operating parameters, such as wood mix and throughput, and to reflect the most recent emissions data from our facilities, so as to ensure continued compliance under the law and the permit being a minor source of emissions under the Clean Air Act.”

Asked where Enviva gets its “most recent emissions data,” particularly for facilities such as Southampton whose current permits do not require HAP testing, and what circumstances — absent any HAP test results — would prompt Enviva to change its emissions estimates, Kravtsova issued the following statement:

“Environmental stewardship is the core of our business and informs everything we do at Enviva. At all of our facilities, we always seek to operate in full compliance with all laws and regulations, at the local, state and federal levels. We have a culture of continuous improvement at Enviva and perform periodic testing as required under the applicable permits at our facilities. We use that test data to inform and improve our processes company-wide. This includes periodically updating emission factors under the permits to reflect the most recent emissions data from our facilities or changes in operating parameters such as wood mix or throughput. From the day we commenced operations, our Southampton facility has consistently demonstrated compliance with the terms of its existing permit.”

“After the currently-proposed permit is issued and the control technology is installed, Southampton will be among the most, if not the most, stringently-controlled wood pellet manufacturing facilities in the world,” Kravtsova said. “It will also be subject to strict testing and reporting requirements to ensure our continued compliance with the Clean Air Act. We are proud to be an industry leader in environmental stewardship in air emissions controls, as in other areas of our business.”

Editor’s note: A previously published version of this story incorrectly spelled Tamera Thompson’s name as “Tamara Thompson.”