COMMUNITY Q & A (part 1)
Updated: Jan 7
Madison County Clean Power Coalition
Community Meeting Madison County High School Cafeteria
at 7pm on December 5, 2019
Questions from the public answered by Madison County Clean Power Coalition (MCCPC)
1. Is Georgia Renewable Power permitted to burn and form of municipal solid waste? (example – household garbage?) What specific feed stocks/fuels are allowed to be burned by Georgia Renewable Power under their existing permits?
GRP is permitted to burn construction and demolition wood as well as all kinds of wooden railroad crossties. Aside from concerns about the crossties, the EPA requires construction and demolition wood to be cleaned “to best management practices.” The European Union EPA prohibits the burning of construction and demolition wood, believing that best management practices does not get the wood clean enough to avoid producing unacceptable levels of dioxins. The MCCPC agrees with these findings.
To review permitting documents related to GRP, visit https://permitsearch.gaepd.org, go to “facility name” and type in GRP. The Madison County facility will appear in the scroll-down section.
2. a) Do the workers understand how dangerous their work environment is? If so, why is there not a larger concern? Why has the plant been allowed to run this long?
We have been told the workers in the crosstie yard have had training, and their personal protection equipment will be updated within the next few weeks. A complaint was filed with OSHA. There is a question relative to OSHA’s jurisdiction, as anything relating to railroad safety is monitored elsewhere. However, if the salvage company is the employer, OSHA could get involved. OSHA is a bureaucracy, and the results of any report take about 6 months. Why has the plant been allowed to run this long? No agency has the authority to stop it. There is a long history to deregulation in which we, as voters, play an important part. We allowed ourselves to be persuaded that government regulation is bad and elected politicians who favor deregulation. Over the last few decades all regulatory agencies have been severely weakened. Across all branches of government, we now use the fox and chickens model of regulation. If you process chickens, you employ your own inspectors. If you are a drug manufacturer, you run your own clinical studies. And if you want to build a power plant, you provide the data for your applications, and the Georgia Environmental Protection Division (EPD) makes sure all the blanks are filled in.
3. After they burn their waste, what are they doing with the ash that remains?
We have been told, currently ash is being landfilled outside the county. However there are reports some local farmers have obtained ash and are spreading it on their fields. The plant management claims that ash can be spread on fields by farmers. We recommend testing of the ash before any use for farming is considered.
4. How far should you be out of the “stink zone?” (health concern)
If you are in the “stink zone” then you are breathing some gases emitted from the plant. That does not mean that you are seriously exposed, but you should be aware that any health problems you experience could be related to plant emissions.
5. What is causing the black soot that is coating the area?
The black soot is particulate matter coming from the stack at the plant. Particulate matter can be very dangerous to health when inhaled. Short- and long-term exposures can be detrimental to health depending on the degree of exposure and the current health of the person affected.
6. a) Is GRP willing to make changes to be a good neighbor?
GRP/Veolia has said many times, both publicly and privately they want very much to work with the community. They also have stated they want to be a good neighbor. They have assured us they are in the process of addressing the many concerns of Madison County residents. We have not yet seen any remedies put into place, but we have contacted the EPD and multiple organizations to enforce change.
b) Can the biomass plant operate using other material other than creosote rail road ties?
Yes, the plant can operate using just clean cellulosic biomass, as originally permitted. The plant operators assure us they have enough to operate without using the railroad ties.
c) Why does the plant operate after midnight?
Startup and shutdown are long processes, and the plant sells electricity to Georgia Power at all times.
d) Will the burning of rail road ties remain a part of this power plant’s power production?
This is unclear. The MCCPC is trying to stop this practice, but GRP/Veolia is currently permitted to do so.
7. a) Have water, soil, and/or gaseous samples been collected and tested for known toxins in the immediate vicinity of the biomass power plant? b) If so, have the results of these tests come back? c) What do the data based predictions/projections look like?
The companies claim there is regular testing, but the consistent negative results of chemicals in soil or pond water are suspect. Water testing for pollutants is extremely specialized. Depending upon what chemical you are testing for, you may have to test the surface, mid-water, or sediment. Moving water has its own concerns. Simply dipping a sterile vial into a pond won’t produce accurate results.
b. If so, have the results of these tests come back? The claim from GRP and National Salvage is, the surface runoff anywhere on the property contains no chemicals. This statement defies logic.
c. What do the data based predictions/projections look like? We don’t have any data yet.
8. a) When did the plant begin to burn railroad ties? b) Was there a public announcement/warning?
State law didn’t require the company to advertise the permitting change in the county’s legal organ. A public advisory was issued by the GA EPD regarding the permit change and there was a 30 day comment period from March 6-April 5, 2019. No public comment was received. However in order to get these advisories, you have to sign up with the EPD to receive the weekly emails. Only 4200 GA citizens of the entire population currently receive the notifications.
9. a) What efforts are being made to catch run off? b) What happens to water if the plant is built on very sandy or candy rock soil that the water runs through quickly? c) How is this evaluated and by whom? d) How and who evaluates clay layers vs. candy rock soil?
We have observed minimal stormwater abatement: corrugated pipe to slow water coming off parking area, riprap at the base of a PVC pipe, some staked haybales in a drainage ditch, and haybales to catch debris around a catch basin in the center of the crosstie yard. Some measures in the crosstie yard exacerbate the pollution issue. For example, the cement pad in the crosstie yard is sloped down toward the pond/wetland. This speeds up erosion and more efficiently delivers pollutants into the groundwater system
b. What happens to water if the plant is built on very sandy or candy rock soil that the water runs through quickly? I am unclear on “candy rock soil,” but I have consulted a soil scientist and am waiting to hear back. Sandy soil can be a sort of filter for some things. But because it is permeable, water continues to flow downward. Therefore, chemicals in solution would continue into an aquifer which supplies area wells.
c. How is this evaluated and by whom?
d. How and who evaluates clay layers vs. candy rock soil? We are trying to find out if an environmental impact study was EVER done for this site (GRP or Weyerhaeuser)
10. How can we test our ground water and air for pollutants?
You can test your well water but the test by the USDA will not test for creosote in the water. This will require a special test. We are asking the plant to test well water in the vicinity of the plant, but this is not yet being done.
11. Is there a purification process to clean the railroad ties?
The railroad ties are not cleaned before processing. They are shredded and metal parts removed with a magnet, and then they are fed into the plant. Processes exist for removing creosote from crossties and recycling it before burning the ties. GRP is not equipped to do this.
12. How can we stop GRP from burning railroad ties?
Possible solutions: 1) Get EPA to rescind the 2016 amendment to the Federal Register which allowed the burning of creosote RR ties https://www.govinfo.gov/content/pkg/FR-2018-02-07/pdf/2018-02337.pdf 2) Negotiate with GRP 3) Public Outcry 4) Get county & state officials to support cause.
13. How far is the creosote dust traveling?
We only will know this by doing soil samples. The dust from the wood chip pile is blowing sawdust, and sawdust with creosote at least a few hundred yards over pasture.
14. a) How can dust be controlled at the plants? b) What efforts have been made to contain dust?
We see dust at the plant daily with little evidence of dust control. Sometimes there is a heavy stream of water aimed at the back of the wood chip pile. This may be a dust control measure.
15. Is the creosote toxic to birds and bees?
Yes, the creosote is a pesticide that can kill birds and bees or make them very sick. The wood preservatives in crossties also contain toxic chemicals that slow fungal growth, and contaminants from years of use.
16. What is the range that this air pollution can travel?
In events such as volcano eruptions, soot can travel hundreds of miles. Many factors: wind velocity, size/shape of particle. Studies suggest most airborne pollutants from a power plant drop within a half mile of the plant. Studies show pollutants from plants like the one here can travel 20 miles or more. The pollution decreases as it travels farther from the plant.
17. a) What engineering controls are in place at GRP? b) Are these controls sufficient to mitigate the known chemicals of public health concern produced by the burning of biomass materials? c) How often will it be replaced? d) Is it safe when it gets dirty?
The plant does not actually have a single filter. Instead, it has emissions control devices. Currently the plant has an electrostatic precipitator and a selective catalytic reduction system installed. These two emissions controls are designed to trap particulate matter and noxious gases. The plant has three other emissions control devices listed in its application for a permit, but they have not installed those yet, and may not according to plant operators. The plant operators told us that the current emissions control devices are adequate.
From our perspective, no, the controls are not sufficient. The specific equipment consists of: Electrostatic Precipitator, Bag, and Cyclone for particulates, Selective Catalytic Reduction System for nitrogen oxides, Oxidation Catalyst installed for CO2 but also reduces polyaromatic hydrocarbons, Dry Sorbent Injection for sulfate. With regard to the bag, getting dirty is not an issue. It will be replaced when damaged.
18. Is it true that CSX is paying GRP to take the ties?
CSX pays National Salvage to pick up the old RR ties, National Salvage transports them to the GRP yard, sorts the ties and sells the best ones to retailers to be used for landscaping, chips the remaining ties, and GRP pays National Salvage for the chipped ties.
19. What is “clean c&d” and how is it produced?
Clean C and D is supposed to be the clean wood that is left from construction sites, like butt ends of lumber. The plant is not allowed to burn wood that is treated, but we don’t know how they will monitor this.
20. a) Who samples the air emissions out of the smoke stack? b) Where are the waste by products disposed of? c) What was done with the cross ties before GRP contracted to burn them?
GRP’s operators (Veolia) samples the plant emissions and reports them to the State Environmental Protection Division. The waste ash is buried in a landfill outside the county. The cross ties are picked up at the side of the tracks by a salvage company and transported by them to the plant, where they are stored for use.
If the crossties are not shredded and burned for fuel, they were/are generally stored in a landfill. State regulations vary. Some states permit burning crossties as biomass and others don’t.
21. a) Ever since GRP started burning railroad ties, my eyes burn and itch, is this a form of creosote poisoning, and are there other symptoms I need to be aware of? b) How will our decreased air quality affect those with asthma and COPD? c) If an individual has a compromised immune system (cancer survivor) will the creosote in the air affect them adversely?
Your eyes are burning due to the plant emissions. Several types of emissions from the plant can cause your symptoms, including soot and gases that are carcinogenic. Other symptoms can range from a chronic cough to skin irritation to nausea and headaches. Those persons who already have health problems, especially asthma or COPD or bronchitis, are more likely to suffer worse effects from the additional pollution, and need to take protective measures. Persons who are immune-compromised may also be at higher risk.
22. What is the biomagnification / bioaccumulation risk of eating animals exposed to all of this? (poultry and beef production, deer meat)
First, two definitions:
Bioaccumulation: Amount of a toxic substance builds over time. An animal eats substances containing toxic material (such as cattle eating creosote dust on a pasture). With many toxic substances, it builds in the body faster than the body can eliminate it. Over time, the accumulation of the toxic substance kills the animal.
Biomagnification: A toxic chemical increases in amount each time it moves up the food chain. For example, some worms eat soil with creosote compounds. Next, since a bird is much larger, a bird eats many of the toxic worms. And finally, perhaps a fox eats a couple of the highly toxic birds… etc.
There is no way to assess either of these without taking multiple samples of crops and livestock. The biggest concern would be livestock in the pastures next to the biomass plant. Depending upon the length of time they are in the field, they could suffer from substantial bioaccumulation.