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Updated: Nov 3, 2021
NPDES Wastewater Permit Application
Here is further information on the upcoming NPDES Wastewater permit made by GRP. The time for public comment will end March 5, 2021. We need your voice to protect our county.
Below are the methods by which you can make public comment. Also, please see the entire application submitted.
Public Comment & Public Hearing -Two page notice from EPD calling for public comment in writing by March 5 and/or by attending Zoom Public Hearing on March 2.
Draft Permit: 66-page draft permit, including, among other regulations and measurements, anticipated effluent composition and characteristics.
Permit application: GRP NPDES application and documentation
Newspaper article: Excellent summary of the dangers and questions regarding the GRP wastewater permit.
MCCPC Joins BREDL
Madison County Clean Power Coalition has teamed up with BREDL (Blue Ridge Environmental Defense League). BREDL is a community action group spanning the entire southeast of the US. Through BREDL, MCCPC has attained non-profit status (501c3) which gives us access to legal assistance as well as organizational information as we progress forward. Visit BREDL's site: http://bredl.org/
EPD Answers Community Questions
Karen Hays, responds to questions from 12/5/19 community meeting:
1. Is Georgia Renewable Power permitted to burn and form of municipal solid waste? (example – household garbage?).
EPD response: No, Georgia Renewable Power (GRP) is not permitted to burn municipal solid waste.
2. What specific feed stocks/fuels are allowed to be burned by Georgia Renewable Power under their existing permits?
EPD response: GRP is allowed to burn clean cellulosic biomass, which can include clean construction and demolition wood and railroad ties. Definitions, details, and restrictions are contained in three permit conditions, which are shown below:
Permit condition 2.5 (both GRP Madison and GRP Franklin):
The Permittee shall only fire clean cellulosic biomass, which may include clean construction and demolition wood, creosote treated railroad ties, creosote-borate treated railroad ties, copper naphthenate treated railroad ties, copper naphthenate-borate treated railroad ties, and distillate fuel oil in the boiler (Source Code: B001). “Clean cellulosic biomass”, “creosote treated railroad ties”, “creosote-borate treated railroad ties”, “copper naphthenate treated railroad ties”, and “copper naphthenate-borate treated railroad ties” are defined in Condition 2.9 and 40 CFR 241.
Permit condition 2.9 (both GRP Madison and GRP Franklin):
For the purposes of this Permit:
Clean cellulosic biomass means those residuals that are akin to traditional cellulosic biomass, including, but not limited to: Agricultural and forest-derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, tree harvesting residuals from logging and sawmill materials, hogged fuel, wood pellets, untreated wood pallets); urban wood (e.g., tree trimmings, stumps, and related forest-derived biomass from urban settings); corn stover and other biomass crops used specifically for the production of cellulosic biofuels (e.g., energy cane, other fast growing grasses, byproducts of ethanol natural fermentation processes); bagasse and other crop residues (e.g., peanut shells, vines, orchard trees, hulls, seeds, spent grains, cotton byproducts, corn and peanut production residues, rice milling and grain elevator operation residues); wood collected from forest fire clearance activities, trees and clean wood found in disaster debris, clean biomass from land clearing operations, and clean construction and demolition wood. These fuels are not secondary materials or solid wastes unless discarded. Clean biomass is biomass that does not contain contaminants at concentrations not normally associated with virgin biomass materials.
Any wood that has been treated with compounds such as chromate copper arsenate or comingled with such compounds or lead is not considered clean cellulosic biomass.
“Creosote treated railroad ties” means railway support ties treated with a wood preservative containing creosols and phenols and made from coal tar oil.
“Creosote-borate treated railroad ties” means railroad ties treated with a wood preservative containing creosols and phenols and made from coal tar oil and borate, including borate made from disodium octaborate tetrahydrate.
“Copper naphthenate treated railroad ties” means railroad ties treated with copper naphthenate made from naphthenic acid and copper salt.
“Copper naphthenate-borate treated railroad ties” means railroad ties treated with copper naphthenate and borate, including borate made from disodium octaborate tetrahydrate.
Permit condition 2.19 (both GRP Madison and GRP Franklin)
Prior to burning creosote treated railroad ties, creosote-borate treated railroad ties, copper naphthenate treated railroad ties, or copper naphthenate-borate treated railroad ties in the boiler (Source Code: B001), the railroad ties shall be processed by, at a minimum, metal removal and shredding or grinding.
3. After they burn their waste, what are they doing with the ash that remains?
EPD response: GRP reported to EPD that the ash is contracted to Cementitious Solutions for removal. GRP stated that Cementitious Solutions sells some of the ash to a farmer who uses it as a lime/nutrient substitute. GRP said the farmer has an approval from the Department of Agriculture. GRP reported the remainder of the ash is removed by Cementitious Solutions is taken to the Gainesville Waste and Recycling facility.
4. Who tests the ash and how often is it tested?
EPD response: GRP stated that the required TCLP (TCLP is an acronym for toxicity characteristic leaching procedure) analysis has been done. EPD has requested the results but has not received them yet.
5. Where is the ash disposed?
EPD response: GRP contracts with Cementitious Solutions to remove and dispose of the ash. Cementitious Solutions sells some of the ash to a farmer and provides the rest of it to the Gainesville Waste and Recycling facility.
6. Have water, soil, and/or gaseous samples been collected and tested for known toxins in the immediate vicinity of the biomass power plant?
a. If so, have the results of these tests come back?
EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which EPD has water quality criteria.
b. What do the data based predictions/projections look like?
EPD response: The facility submitted a national pollutant discharge elimination system (NPDES) permit application which characterized the proposed effluent discharge. However, EPD has asked them to resubmit the application to correct deficiencies in the original submittal.
7. When did the plant begin to burn railroad ties?
a. Was there a public announcement/warning?
EPD Response: GRP received an amendment to their air quality permit in July 2019 to burn railroad ties in the boiler. EPD issued a public advisory for the addition of this new fuel type on June 6, 2018, the advisory was emailed to those on the subscriber list (you can sign up at https://epd.georgia.gov/public-announcements-0/air-protection-branch-public-announcements/subscribe-air-protection-branch) and posted to EPD’s webpage. No comments were received.
8. When will the runoff and ground water be tested for carcinogens?
EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which we have water quality criteria.
a. Is the water paid for and by whom?
9. How can dust be controlled at the plants?
a. What efforts have been made to contain dust? We see dust at the plant daily with no evidence of dust control.
EPD response: Permit Conditions 3.2.1 and 3.2.2 state the air quality rules for fugitive dust (Chapter 391-3-1-.02(2)(n).
Permit condition 3.1 (both GRP Madison and GRP Franklin):
The Permittee shall take all reasonable precautions with any operation, process, handling,
transportation, or storage facilities to prevent fugitive emissions of air contaminants.
Permit condition 3.2 (both GRP Madison and GRP Franklin):
The Permittee shall comply with Georgia Air Quality Control Rules 391-3-1-.02(2)(n),
“Fugitive Dust”, for the entire processing facility including all roadways and processing
equipment not otherwise subject to any other rule or regulation governing fugitive visible
emissions. Subject to this rule, the Permittee shall not cause, let, permit, suffer or allow
visible emissions from any fugitive source to equal or exceed 20 percent opacity.
GRP’s permits require control of the dust emissions or particulate matter (PM) that are generated as a result of their operations. The majority of GRP’s particulate matter (over 99%) is generated by their wood biomass fired stoker boiler (the boiler). Particulate matter from the boiler is controlled via the use of a cyclone and a high voltage electrostatic precipitator (ESP); these devices control particulate matter emissions. The devices have been designed to have an expected control efficiency of 98.8% particulate matter removal efficiency. The allowable particulate matter emission rate from the boiler is 0.03 lb/MMBtu heat input. Required particulate matter performance tests were conducted in November 2019 and final results will be submitted to the Division by the end of January 2020 for review.
The other type of particulate matter emissions is categorized as “fugitive emissions,” (particulate matter emissions that are not released via an emissions stack). GRP has stated to EPD that they are currently working on the following measures to mitigate fugitive emissions:
· GRP is implementing a program to ensure the fuel quality that is delivered to the facility. GRP will ensure that vendors deliver certain sizes of wood chips and refuse sawdust like materials in order to minimize fugitive emissions.
· GRP will install dust suppression spray systems at all fuel transition points to better control dusting.
· GRP is installing a retractable-chute at the fuel stack-out conveyor that can be operated remotely by an operator. The retractable chute will minimize drop heights and minimize fugitive emissions.
· GRP is investing in a fly-ash conditioning system (also known as a pugmill). This system will allow the transfer/loading of fly ash to occur without generating fugitive emissions.
· GRP will implement certain Standard Operating Procedures (SOP), that will direct personnel when to or not to engage in certain activities that could lead to an increase of fugitive emissions.
10. What engineering controls are in place at GRP?
a. Are these controls sufficient to mitigate the known chemicals of public health concern produced by the burning of biomass materials?
EPD Response: Yes. GRP’s air permit application review included an assessment of the expected emissions to ensure that the resulting air quality permit is protective of human health. This assessment (called the Toxic Impact Assessment, or Toxic Guidelines) uses US EPA-developed computer simulations to estimate the offsite concentrations of the air toxics that are expected to be emitted. That value is then compared to a screening level. Based on the information contained in the permit applications submitted by GRP, the concentrations of air toxics were all below the screening level. The facility conducted emissions testing in November 2019 to confirm the results of the assessment. The results of the testing are due to EPD in January for review.
11. Regarding the filter that is supposed to protect the people living close to the plant –
a. How often will it be replaced?
b. Is it safe when it gets dirty?
EPD response: The filter that controls particulate matter emissions is commonly called a “baghouse”. This technology is frequently used by industries to control particulate matter emissions due to the high efficiency. The baghouse has hundreds of filter bags organized in parallel. The filter bags are designed to last several years before replacement. If a filter bag develops a leak, symptoms of that leak will be detected due the use of a “Continuous Opacity Monitor” (COM) that measures the amount of smoke coming out the stack.
The baghouse is equipped with a cleaning mechanism to purge the filter bags periodically. The purged dust goes into a bin to be collected and sent to a landfill.
12. What is “clean c&d” and how is it produced?
EPD response: EPD’s Solid Waste Management Rules do not define “clean c&d” (construction & demolition). However, the rules define Construction/Demolition Waste as “waste building materials and rubble resulting from construction, remodeling, repair, and demolition operations on pavements, houses, commercial buildings and other structures. Such waste includes, but are not limited to asbestos containing waste, wood, bricks, metal, concrete, wall board, paper, cardboard, inert waste landfill material, and other nonputrescible wastes which have a low potential for groundwater contamination” (Solid Waste Management Rules, Chapter 391-3-4-.01(18)). EPD does define “clean concrete” in its guidance for “Use of Recovered Clean Concrete and/or Cured Asphalt as a Structural Fill Material”. In this guidance “clean concrete” is defined as concrete that is free of added paints, insulators, reinforcing materials, sealers, or any other material, which would have a potential for contaminating groundwater.
13. Who monitors the sorting process with c&d materials?
EPD response: GRP is responsible for monitoring the C&D materials generated on-site and properly processing or transporting it to a solid waste handling/disposal or recovered materials site. EPD requested GRP review all of their solid waste streams to ensure that solid waste is being directed to the appropriate facility.
14. a. Who samples the air emissions out of the smoke stack? b. Where are the waste by products disposed of?
EPD response: The primary waste by-product is ash. As noted in the responses for questions 4 & 7, GRP has stated that the ash is being taken to a farmer for land application and to the Gainesville Waste and Recycling facility.
15. Is it too late to prevent soil and water pollution if the plant removes the cross ties and stops burning them?
EPD response: EPD has issued a Notice of Violation dated December 9, 2019 for violations of the Georgia Water Quality Control Act. EPD will ensure that the facility gets into compliance, which will protect from harm resulting from water pollution.
16. Has the EPA amended the NHSM (non-hazardous secondary materials) under RCRA to identify whether non-hazardous secondary materials are solid wastes when used as fuel or ingredients?
a. Specifically – did they add creosote treated railroad ties that are processed and combusted in units designed to burn both biomass and fuel oil?
EPD response: Yes, in EPA’s February 7, 2018 final rule to amend the CFR part 241 standards for combustion of Non-Hazardous Secondary Materials, creosote-borate and mixtures of creosote, copper naphthenate and copper naphthenate-borate treated railroad ties were added to the list of categorical non-waste fuels that can be burned in units designed to burn both biomass and fuel oil.
b. Has the stream water been tested? (suggested – implement testing of water, land, and air for chemicals)
EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which EPD has water quality criteria.
17. When will the burning of railroad ties end?!
a. How is it they are allowed to burn the railroad ties?
EPD response to a. and b.: The air quality permit amendments issued to GRP’s Franklin and Madison facilities in April 2019 allow the burning of clean cellulosic biomass, which can include clean construction and demolition wood and railroad ties. Details, restrictions and definitions are contained in the three permit conditions listed under Question 2.
b. Why is this permitted?
EPD response: The Air Protection Branch’s Stationary Source Permitting Program reviewed GRP’s applications requesting to be allowed to burn up to 20% railroad ties in the boilers and determined that:
· US EPA approved environmental regulations classifying railroad ties as “not solid waste” for use as fuel in boilers provided that certain requirements are met.
· The emissions resulting from combustion of railroad ties in the boiler are not expected to be significantly different from the emissions from burning only “clean cellulosic biomass” as originally permitted.
· There are no environmental provisions or reasons prohibiting the use of railroad ties as fuel in a well-controlled boiler.
c. What legal background allows the burning of crossties?
EPD response: In 2018 EPA finalized changes to 40 CFR 241.4 (Non-Waste Determinations for Specific Non-Hazardous Secondary Materials When Used as a Fuel) that added “Creosote-borate treated railroad ties, and mixtures of creosote, borate and/or copper naphthenate treated railroad ties” to the list of non-hazardous secondary materials that are not solid wastes when used as a fuel in a combustion unit. Processing must include, at a minimum, metal removal and shredding or grinding.
18. Why doesn’t EPA Permitting make sure permits are put in county legal organ?
EPD response on the air quality permitting process: Georgia EPD follows the procedures and rules set forth by our agreement with US EPA (called the State Implementation Plan). That plan does not require public notice in a legal organ for a construction permit, which is the type of permit currently issued to GRP Franklin and GRP Madison. GRP Franklin and GRP Madison are subject to 40 CFR 70, and must submit a Part 70 permit application within 12 months of commencing operations. The draft Part 70 operating permit will require a public notice in the appropriate legal organ prior to the final permit being issued.
EPD response on the wastewater permitting process: EPA has regulations (40 CFR Part 124) requiring public notice of national pollutant discharge elimination system permits for discharges to waters of the U.S. The Georgia Water Quality Control Act requires public participation prior to a wastewater permit being issued for either discharges to waters of the state or discharges to a land treatment system. The type of public notice varies depending on the size of the facility and wastewater disposal method. Upon review of a wastewater permit application, at a minimum EPD will publish a public notice on our website to solicit comments from the public and the regulated entity will post a notice at a public location.
19. Who signed (and why) the permit that allowed GRP to burn railroad ties?
EPD response: All Air Quality Permits in Georgia are signed by EPD Director Richard Dunn, however the permit review, draft permit development, and recommendation to approve the draft permit are conducted by the Air Protection Branch’s Stationary Source Permitting Program (SSPP). SSPP reviewed GRP’s application and determined that:
· US EPA revised their environmental regulations classifying railroad ties as “not solid waste” for use as fuel in boilers provided that certain requirements are met.
· The emissions resulting from combustion of railroad ties in the boiler are not expected to be significantly different from the emissions from burning only “clean cellulosic biomass” as originally permitted.
· There are no environmental provisions or reasons prohibiting the use of railroad ties as fuel in a well-controlled boiler.
20. Do they have a permit to burn chicken litter?
EPD Response: No, they do not have permit to burn chicken litter. The GRP Franklin plant does sit on the site originally permitted as “Plant Carl”, a small chicken litter boiler that was permitted but was never built.
35. Does the plant have electrostatic precipitators and scrubbers installed?
a. If so, are they wet scrubbers?
b. If a wet scrubber, what is done with the water that was used to filter the material that is scrubbed?
c. What is being done with the material that is scrubbed?
EPD Response: GRP Franklin and GRP Madison use an electrostatic precipitator (ESP) but do not use a scrubber. The dust/soot collected in the ESP is shipped to a landfill via truck.
21. May be a redundant question, but what is being done with the ash of any material after it is burned?
EPD response: The primary waste by-product is ash. As noted in the responses for questions 4, 7, and 29a, GRP has stated that the ash is being taken to a farmer for land application and to the Gainesville Waste and Recycling facility.
22. What is being done to monitor the emissions from the stack and who monitors that?
EPD response: Emissions tests were conducted in November 2019 to demonstrate that GRP Franklin and GRP Madison are complying with emiss
ion limits for the following pollutants: 1,2 dibromoethane, hydrogen chloride, arsenic, chromium, lead, silver, volatile organic compounds (generally referred to as VOCs), and particulate matter (PM). The testing for VOCs was added when the permit was amended in 2019 to allow burning railroad ties as fuel in the boiler.
GRP is also required to continuously monitor emissions of nitrogen oxides (NOx) and carbon monoxide (CO) as well as the opacity of the smoke leaving the stack.
The emissions tests are conducted by a third party company, and the test results are analyzed by a certified laboratory. EPD reviewed the test plans prior to the tests and was onsite for the emissions testing. The test results will be are submitted to EPD for review in January 2020.
The facility operations are monitored by EPD using periodic testing, onsite inspection, and review of required records and report
From Our Scientists
Biomass power plants are controversial. While it might be economically advantageous to burn scrap wood and railroad ties, the health risks far outweigh any economic gain.
Statement from the American Lung Association
“The main risks to health from burning “clean” biomass are the unhealthy gases that it gives off and the particulate matter that escapes into the air. Several national health organizations, including the American Lung Association and the American Heart Association are on record as being opposed to biomass plants. Their emissions of pollutants such as sulfur dioxide and nitrogen oxides, along with their release of large amounts of carbon dioxide, carbon monoxide, and particulate matter pose serious health risks."
12/5/19 Presentation by David Ramsey, MPH
My part of the presentation is to inform you about the characteristics of the railroad crossties and other products being burned at the GRP plants, and the toxic effects on our health from their handling, burning, and leaching into our environment. I will also report on what a number of state and national health organizations have said about burning biomass and their announcements to the public about the resulting health hazards.
Let’s start with creosote, one of the hazardous substances that has already been mentioned. The creosote that goes into the crossties is referred to as coal tar, or coal tar creosote. It is a syrupy, semisolid mix of many chemicals that is put into the railroad tie by one of several processes.
How much creosote is in each one of the crossties? According to the Railway Tie Association, which is an industry group that has represented railway crosstie manufacturers and marketers for over a hundred years, the average new crosstie has 20 pounds or more of creosote in it. The Railway Tie Association knows a lot about railroad crossties and one of the things they have studied is how long the creosote stays in the crosstie throughout its life of service. What they determined is that on average, a crosstie loses about one percent of its creosote each year over its lifetime. So, a crosstie that is 25 years old would lose about 25% of its creosote. That means that on average a crosstie being taken out of service at 25 years will still have 75% of its creosote contained in the tie. That works out to about 15 pounds, on average, of creosote that will be in each railroad tie like the ones you have seen stacked on the property of the biomass plants. So, if there are 1000 railroad ties stacked up on the plant site, there is about 15,000 pounds of creosote sitting at the site in those crossties (about ¾ of a ton of creosote). You may have heard reports of a study done in North Carolina that says that used railroad ties only have about 6% of their creosote remaining at the end of their service life. We have made efforts to find that study, but the U. S. Environmental Protection Agency, the Railway Tie Association, and the North Carolina Department of Health and Human Services have not yet been able to direct us to such a study.
Dr. Vogel mentioned that creosote itself is a known human carcinogen. There is widespread agreement within the health community about that. He also mentioned that creosote contains many compounds within it, and when heated they rapidly break up and form different gases. At least nine of these gases, and as many as eight others, are also recognized within the health community as known or suspected human carcinogens on their own. These volatile organic compounds that are burned off as gases make up about 85% of the creosote. They have been known not only to cause cancer, but also many lung and respiratory system diseases like asthma, also heart and cardiovascular disease, and diseases of the stomach, intestines, liver, and kidney. Creosote and some of its components have been shown in studies to be stored in body fat and can remain there for a long time. Creosote has also been found in breast milk, and studies show that it can cross the placental barrier and go into the tissues of the unborn child.
So how does creosote get into our bodies? The creosote and its gases get into our bodies in three different ways. One way it can enter is through direct contact with the creosote, by handling railroad ties or dust from the railroad ties containing the creosote, or by having our skin exposed to the soot or gases coming from creosote.
A second way it can be absorbed into our bodies is through swallowing creosote in the dust from the grinding or sawing of creosote crossties, or through ingestion of soil or water that has been contaminated by creosote. Plant workers are especially at risk to dust that is contaminated by creosote. Some places where creosote has been stored such as crosstie treatment plants have seen contamination of the well water in the vicinity. It can also be ingested by eating plants or animals that have been exposed to creosote in the air, water, or soil. Creosote is hazardous to other species besides humans, and it is especially toxic to aquatic species like fish and shellfish. When creosote gets into the water it can stay there for a long time because it forms a tarry sludge on the bottom and slowly releases contaminants.
The third route of entry into our bodies by creosote is through inhalation. Again, workers who handle the railroad ties are at high risk of inhalation of creosote through inhalation of the dust when the ties are ground, through being constantly in the vicinity of the fumes from the ties, and from being in the immediate vicinity of the plant’s stack. Workers at the plant face many health threats due to the creosote, and they must be fully protected at all times, and their families must also be protected due to the risk of transmission of creosote on the worker’s clothing, hair, and skin. Most of us will not be in direct contact with the railroad ties. But the risks of inhalation are very high because the toxic gases enter the body very easily. When the gases are released from the stack at the plant, they will be dispersed into the community, and we will breathe them in throughout the day and every day in various concentrations, depending on our exposure. Some of the toxic gases will be trapped by the plant’s pollution control devices. But some of the gases will escape the traps and exit the stack into the air. Several of these gases are very hazardous to our health even in small quantities, and as I said before, they can accumulate within our bodies over time.
An additional ingredient that is dangerous to be inhaled is the soot and ash that is created by the burning of the woody part of the railroad ties and the wood chips and construction debris. When these are burned part of the burned wood drops through the grate and is captured within the plant. Part of the burned wood leaves the stack as soot or ash. Some of the soot and ash is trapped by the plant’s pollution control devices, and some escapes into the air. The soot is called “particulate matter” as a general term. Particulate matter is of different sizes coming from the stack. Most of the particulate matter that will be released from the plant is small particulates. The smaller the particulate matter the deeper it can go into the lungs when breathed in. So when particulate matter is inhaled by us, or by our animals or pets, or when it lands in our environment, it can be easily absorbed and can cause several serious health effects, especially diseases of the heart and lungs. Particulate matter can be especially dangerous for children, the elderly, and those persons with existing health problems like asthma, chronic bronchitis, heart disease, chronic obstructive pulmonary disease, and diabetes. In addition, the toxic gases that are being released with the particulate matter can attach to it, and take a ride on it for long distances, depending on the direction of prevailing winds. So you can be exposed to the particulate matter and the toxic gases even if you are a long distance away.
I would like to mention something that hasn’t gotten much attention, because we have been focusing on creosote-treated railroad ties. GRP also received a permit to burn other types of railroad ties.. They will have different mixtures of several chemicals. The mixtures are creosote mixed with borate, copper mixed with napthenate, and copper mixed with napthenate and borate. The creosote-borate railroad ties are considered toxic due to the creosote as described earlier. The copper-napthenate railroad ties are considered moderately toxic, and precautions are recommended for workers handling these ties. The railroad ties containing copper, napthenate, and borate have health effects similar to the copper-napthenate ties. Inhalation of the fumes from these ties can cause headache, nausea, and nasal congestion.
Because all of these railroad ties are toxic to aquatic species, the government has recommended that the ties be stored at least 100 feet from any pond, river, or stream. They should not be stored on bare ground, runoff should be prevented, and the ties should be covered to prevent rain exposure.
Some treated wood that is not a crosstie (wood labeled as construction and demolition material) that may be received as biomass at the plant can also be very hazardous. Wood treated with a solution of chromium copper arsenate (CCA) is very hazardous to health. Since the treatment of wood with this mixture was banned for residential use in 2003, it may not be received in large quantities. But wood coming from tear down of buildings could be in the feed mix. Arsenic is a known human carcinogen and could be a threat to plant workers if they handle it without protection. It is extremely dangerous if it gets into the water supply because drinking arsenic in very small amounts can affect many of our vital organs. Another treated wood that could be hazardous and be received at the plant is wood treated with pentachlorophenol, or “Penta” or PCP as it is sometimes called. The International Agency for Research on Cancer has designated penta as a probable human carcinogen. Penta treated wood has been banned for public use since 1984, so it is likely to be in the plant’s feed mix in very low quantities as tear down from older buildings. Plant workers are most at risk for exposure, but penta treated wood can be released into the atmosphere and inhaled. Long term exposure to penta can cause damage to the liver, kidneys, blood, and nervous system. We are concerned that workers processing the wood at the power plant are not adequately protected from these health risks.
The plant was originally approved to burn “clean” biomass. Creosote added to the biomass makes it much more dangerous to health. Many health organizations have determined that creosote is a suspected or known human carcinogen. The EPA still stands by its statement, in place since 1988, that “the potential for many types of hazardous pollutants to be included with creosote wastes seriously diminishes the potential for recycling or reuse”. This statement, which is still on the EPA website, contradicts the allowance made in 2016 to define creosote treated crossties as a non-hazardous wood that can be recycled. Before 2016 the creosote crossties could not be burned at the Franklin County and Madison County plants because EPA said they were too hazardous to health. Now they can be burned. What has changed? Nothing, except the definition of what type of solid waste it is. Despite the contradiction in the EPA statements, many other government health agencies are on record about the health risks. The Agency for Toxic Substances and Disease Registry agrees with other health agencies that creosote is a suspected or known carcinogen. The International Agency on Cancer Research recently upgraded its statement on creosote from a probable human carcinogen to a known human carcinogen. The same Agency has also declared particulate matter to be a suspected human carcinogen. The National Institutes of Health has determined that creosote as coal tars are known to be human carcinogens based on sufficient studies in humans. The U.S. Department of Health and Human Services National Toxicology Program classifies coal tar and coal tar pitches to be known human carcinogens, and has also declared that 15 of the toxic gases contained in creosote are reasonably expected to be human carcinogens.
An additional pollutant from the plant is noise pollution. Noise is measured in decibels. Evening and night time noise is considered most threatening to health as compared to the same day time noise. Noise below 30 decibels is thought to be of no threat to health. Noise levels from 30 to 40 decibels can have moderate effects, such as disturbing sleep. Children, the elderly, and persons who are chronically ill can be more adversely affected. Between 40 and 55 decibels, there can be short- and long-term health effects depending on the frequency and duration of the noise. Annoyance, sleep deprivation, and increases in blood pressure have been shown. Children have been affected and have shown that attention and concentration at school are affected. Tinnitus (ringing in the ears) can occur between 40 and 55 decibel exposures. Above 55 decibels, there can be serious health problems. Long term exposure can lead to cardiovascular disease, hypertension, mental health problems, and possibly endocrine problems such as diabetes. Hearing loss, falls, and accidents are often associated with this level of exposure. The EPA and the World Health Organization have established that exposure to noise beyond 70 decibels for a 24-hour period is related to severe health effects, depending on frequency and duration of exposure, and community and personal preventive measures are highly recommended.
The main risks to health from burning “clean” biomass are the unhealthy gases that it gives off and the particulate matter that escapes into the air. Many health organizations are on record as being opposed to biomass plants in general because of the serious dangers to health. Several national health organizations, including the American Lung Association and the American Heart Association, are in opposition to biomass plants in general because of their emissions of pollutants such as sulfur dioxide and nitrogen oxides, along with their release of large amounts of carbon dioxide, carbon monoxide, and particulate matter. We have provided a handout with a statement from several national health organizations who are opposed to the burning of biomass because of the serious health effects on individuals and the community.
In summary, we hope that you are now more aware of the dangers posed by the burning of biomass, creosote-treated railroad ties, and other railroad ties also treated with toxic materials, that you are aware of the very serious risks of exposure to these toxins and the particulate matter that can carry them long distances, and is a toxic substance in its own right, and of the dangers that creosote and its gaseous components pose to our land, air, and water. You are now aware that GRP has not shown that it can verify which of each month’s tons of VOC’s that are coming from the plant’s stack are one or more of the gases that are considered human carcinogens, nor can GRP tell us how much of the runoff from the stored crossties is entering our groundwater and our streams.
Groundwater Protection
Results from lab tests done on samples of air, water, and soil will be posted soon. We will also post any measures taken by Madison GRP to mitigate stormwater runoff and associated pollution..
Permits Issued to National Salvage for Stormwater Runoff
Click here to view permit