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FRANKLIN

On Nov. 18, the Virginia Department of Environmental Quality issued Enviva Pellets Southampton LLC a new air permit, which will allow the company to modify and expand its wood pellet manufacturing facility. Enviva had gone public with its expansion plans last December, announcing that its parent company, Enviva Partners LP, would invest roughly $75.7 million to upgrade the Southampton County plant.

Public comments submitted during the DEQ’s Sept. 12 public hearing on the matter at Camp Community College, and during the agency’s public comment window from Aug. 11 through Sept. 27, however, persuaded the agency to mandate in the permit that Enviva conduct more frequent air emissions testing and submit to more frequent inspections.

According to Stanley Faggert, minor new source review coordinator for the DEQ, the version of the permit the agency had drafted prior to the public hearing and comment period had required Enviva to perform initial emissions stack tests for several air pollutants, upon completion of the installation of new pollution control devices known as regenerative thermal oxidizers (RTOs). It further required that those stack tests be repeated every five years for each RTO.

“After considering the public comments, the permit now requires that many of the stack tests be repeated every year; i.e. five times more frequently,” Faggert said. “These are complicated and costly tests that are performed by a certified third-party company and witnessed and verified by DEQ.”

The draft permit, prior to the public comment period, had also required Enviva to perform weekly visible emission observations to check for and address any fugitive dust escaping the facility. After considering the public comments, the permit now requires that these weekly checks include an evaluation of the facility’s dust control measures in an effort to address any problems with these systems before problems occur, he said.

The third change to the permit resulting from the public comment period, Faggert said, now mandates that Enviva keep records directly calculating the facility’s monthly and annual emissions, using the emissions estimates that the company reported to the DEQ during its permit application, unless the stack tests show that higher emissions figures should be used. Prior to the public comment period, the draft permit had only required Enviva to keep records of air pollution control device operating parameters, which he said include flow rates, temperatures and processing rates, among other factors.

A fourth change to the permit concerns what air emissions limits will apply during the 12-month construction timeframe for the RTOs. Faggert explained that the draft permit, prior to the comment period, had required Enviva to continue complying with its current operating limit of roughly 535,000 tons of wood pellets per year during the construction period, after which the facility would be permitted to increase production to roughly 781,000 tons per year, using mostly softwood instead of mostly hardwood.

“Although it was always DEQ’s intention that the 2015 permit’s emission limits would continue to apply during the 12-month construction period, the permit now explicitly specifies this requirement,” Faggert explained.

Citing letters between Enviva officials and the DEQ, The Tidewater News had reported earlier this year that the company’s December 2018 expansion announcement may have been made with the intention of delaying a DEQ investigation into allegations that the Southampton plant had, for years, been producing emissions in excess of its then-current DEQ air permit, and possibly also in excess of a threshold set fourth in the federal Clean Air Act to differentiate between major and minor sources of pollution. One such letter from the DEQ, dated June 12, 2018, had stated 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 [minor] source for hazardous air pollutants (HAPs), and may actually be operating as a major source of HAPs without the appropriate permit.” The paper’s investigation of this matter revealed that in July 2018, during a meeting with DEQ Director David Paylor and other agency officials, Enviva representatives had claimed to have expansion plans for the facility that predated the DEQ’s June 12, 2018 request for testing, and would include pollution controls to significantly reduce total VOC and HAP emissions. The company subsequently negotiated an agreement with the agency to be allowed to delay the testing until the planned expansion was completed.

Despite the DEQ’s allegation in 2018 that the Enviva Southampton facility may be a major source of HAPs (10 or more tons per year for individual HAPs or 25 or more tons of total HAPs), Faggert confirmed that the 2019 permit the agency issued this week still considers Enviva Southampton to be a minor source. It is, however, considered a Title V major source for VOCs — even though its VOC emissions, with the new pollution controls, are expected to be below the federal 100 ton-per-year standard — because its potential particulate matter, nitrogen oxide and carbon monoxide emissions are still above this threshold.

Enviva Southampton had already been classified as a major source of VOCs in its 2015 permit, Faggert clarified, and therefore, is already subject record-keeping and reporting requirements associated with the federal Title V permitting program. The new testing and record-keeping requirements mandated by the DEQ are solely the result of comments received during the public comment period, Faggert said, and any additional Title V requirements that result from Enviva’s modification and expansion will be addressed during a separate permitting process.

Enviva issued its own press release on Nov. 20 regarding its receipt of the new air permit, in which Enviva Partners LP Chairman and CEO John Keppler is reported to have made the following statement:

“Thank you to Virginia DEQ for their extensive diligence and review of our permit request, as well as for their thoughtful efforts to hear and include comments and input from all stakeholders during the process.”

“This permit comes at an important time. The urgency to address climate change has never been more acute. The United Nations Intergovernmental Panel on Climate Change (IPCC) — widely considered the world’s leading authority on climate science — calls for increased use of bioenergy like Enviva’s wood pellets in every one of their proposed pathways to limiting the impact of climate change to less than 1.5 degrees Celsius. This is because scientific support for renewable wood energy is clear: bioenergy is a critical part of an all-in renewable energy solution to climate change. In September 2019, more than 100 forest scientists from over 50 universities joined the IPCC in embracing the environmental benefits of bioenergy like wood pellets, noting: ‘The long-term benefits of forest biomass energy are well-established in science literature.’ We look forward to continuing to help Virginia be a leader in renewable energy and lessening worldwide dependence on coal.”

“Enviva is constantly investing. We invest in people — both those who wear the Enviva brand as they work, as well as those who live in and around our facilities. We invest in communities where we operate to maintain good jobs, quality local schools, local EMS, and first responders. We also invest in our facilities to ensure that we exceed the requirements and standards set forth by the Clean Air Act, as well as state and local standards. Enviva’s investments create a positive economic and social impact in the Southampton area and the entire state of Virginia, as well as for the environment. Thanks to everyone who took the time to share their thoughts during the comment period. We’re grateful to be a part of your community.”

Clarification:

The newspaper reported that prior to the public comment period, the draft permit had only required Enviva to keep records of air pollution control device operating parameters. Stanley Faggert of the Virginia Department of Environmental Quality, clarified on Monday that the draft permit had required Enviva to keep records of air pollution control device operating parameters and process operating parameters. He also asked to add to his earlier comments on the required frequency of stack testing going from every five years to every one year, “By requiring these tests on an annual basis, DEQ is committing substantial resources t ensure that Enviva remans in compliance with the permit.”