[Editor’s note: This is the fifth of a multi-part series on Enviva. The sixth will investigate a claim that no new, permanent jobs will result from the proposed $75.7M expansion.]

COURTLAND

An April 26, 2018, report titled “Dirty Deception: How the Wood Biomass Industry Skirts the Clean Air Act” — which Patrick Anderson, counsel for the Environmental Integrity Project, co-authored with fellow Powell Environmental Law attorney Keri Powell, and referenced in his firm’s April 2018 letter to Gov. Ralph Northam — alleges that “after the Georgia Biomass testing showed facilities like this could not comply with their synthetic minor limits without additional controls, Enviva found that the Southampton facility was indeed emitting well above 250 tons [of volatile organic compounds] per year.”

“The first plant in the industry to discover higher-than-expected VOC emissions was Georgia Biomass, in Waycross, Georgia, followed closely by Green Circle Bio Energy in Florida, both in late 2012 and early 2013,” Anderson explained when asked about his report’s allegation. “Based on this information, Enviva conducted VOC tests at its Mississippi plant that confirmed the high VOC emissions.”

The testing at an Enviva plant in Mississippi that Anderson references is the same testing consulting engineer Joe Sullivan referenced in his 2013 letter to the DEQ, which requested an air quality permit modification on behalf of Enviva Southampton.

Anderson’s and Powell’s report further alleges that, rather than installing additional control technology to reduce pollution at the Southampton plant, “plant operators actually removed the pollution control equipment to evade upgrade requirements and switched from processing softwood to hardwood… .”

“That statement is the one part of our report that Enviva has corrected us on, although we weren’t off by much,” Anderson said. “As background, when the plant was first permitted, the permit required the use of a regenerative thermal oxidizer (RTO) on the wood dryer, which reduces VOC and HAP (hazardous air pollutant) emissions by 95 percent or more. Additionally, Enviva planned to process mostly softwood [in 2012], which emits higher levels of VOCs than hardwood, but not necessarily high levels of all HAPs.”

After learning of the test results at the Mississippi Enviva plant, Anderson explained, Enviva Southampton opted to switch to hardwood rather than undergo major source permitting. At the same time, the latter plant requested that the DEQ eliminate the requirement of an RTO from its permit. This is confirmed in Sullivan’s 2013 permit application letter to the DEQ, which states, “As part of this permit application, Enviva is requesting removal of the regenerative thermal oxidizer (RTO) and providing a demonstration that thermal oxidation controls are unnecessary… .”

“Enviva believed that, by processing all hardwood, the facility would not need the RTO to reduce VOC emissions to minor source levels,” Anderson explained. “The mistake we made, however, was that at that point, Enviva had not actually installed the RTO, so they really only removed the requirement to install an RTO from the permit.”

The “Dirty Deception” report then stated that, while switching from processing mostly softwood to mostly hardwood “did allow Enviva Southampton to begin complying with the VOC limit … research and recent testing at other facilities indicates that drying hardwood actually emits certain hazardous air pollutants at higher levels than drying softwood.” It adds that without the RTO requirement, the facility currently is not controlling its hazardous air pollutant emissions in any way.

As previously reported, the proposed $75.7 million expansion of the Southampton County plant will include transitioning the facility to process a higher percentage of softwood, and the installation of four RTOs, as well as other pollution mitigation equipment.

Also reported before was the fact that — 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, these additional emission controls would not be needed — Yana Kravtsova, vice president of environmental affairs and chief compliance officer for Enviva Southampton’s parent company, Enviva Partners LP, did not answer “yes” or “no.” She instead cited stack testing conducted at the Southampton plant this past April, pointing out that these results indicated full compliance with that plant’s 2015 DEQ permit.

Tamera Thompson, manager of the DEQ’s Office of Air Permit Programs, however, had clarified that the testing Enviva had conducted in April had only been for particulate matter and nitrogen oxides, and had not included any results for HAPs or VOCs.

Thompson had also added that if Enviva had not proposed the expansion in the summer of 2018 following the DEQ’s initial request in June 2018 for site-specific HAP and VOC testing at the Southampton facility, the DEQ would have wanted the company to do the testing the agency had originally requested. As a result of the expansion, the DEQ allowed Enviva to delay testing until the expansion was completed and new pollution controls were installed.

Anderson’s Nov. 5, 2018, letter to the DEQ concludes by alleging that if Enviva’s Southampton plant is allowed to delay testing until its expansion is complete, the facility will continue to release “massive amounts of harmful and unlawful HAPs into the neighboring community of Franklin, Virginia,” for at least two more years. His letter then estimated that “based on conservative estimates from 11 sets of stack testing at wood pellet mills across a wide range of hardwood/softwood mixes” the Enviva Southampton plant has “the potential to emit at least 46 tons of HAPs per year — almost double the legal limit… .”

“These unlawful HAP emissions have not occurred in a vacuum. The Southampton facility is located less than three miles from Franklin, Virginia’s elementary, middle and high schools,” Anderson writes. “Additionally, the residential neighborhoods of Franklin located closest to the Enviva Southampton – just two miles to the east of the facility – are predominantly low-income and minority communities, ranking in the 96th and 98th percentile nationally for environmental justice indicators. As the Commonwealth of Virginia has recognized, such communities should not ‘bear disproportionately high or adverse effects from pollution.’”

To ascertain whether locals consider Enviva’s alleged pollution to be a problem, The Tidewater News attempted to speak with residents living in proximity to the Enviva Southampton plant on the evening of Wednesday, July 24. Few appeared to be home that evening, but Robin May, Mason Britt and Darryl Bradshaw — all of whom live on Dogwood Bend, which is just outside Franklin’s city limits and less than a mile from the Enviva Southampton plant — said they had experienced no issues with air quality or any health problems attributable to living near the plant.