Minnesota is rich in blogs, and alternative media such as The Uptake . Is another blog really needed? Good question! My main reason for setting it up is to have a place to archive and link to various emails and posts. Continue Reading →
Comments due Sept 15th: Support shut-down of polluting, resource-destroying incinerator in Benson, MN.
I rarely support actions by Xcel Energy, but this time Xcel is doing the right thing in five matters (for its own reasons, of course). I’ll address these five in separate posts, as Xcel filed five separate matters before the Minnesota Public Utilities Commission. First, this one about the incinerator in Benson, PUC Docket r-002/M-17-530 (when searching PUC’s eDockets or eFiling comments, it’s the 17-530 that’s important).
In one of the dumbest actions ever taken in Minnesota on an energy-related matter, a large “poultry litter” incinerator was built in Benson, Swift County. This was supported by many “environmental” interests in MN, as part of a 1994 deal to keep the Prairie Island nuclear plant operating. It was opposed mainly (only?) by David Morris — Institute for Local Self Reliance. As one would expect, this facility has a horrendous record of pollution and environmental violations. Its air emissions permit expired in 2008. Xcel is proposing to buy the facility and shut it down. This is good news. Xcel generally gets what it wants, (regardless of whether it should). The stated reason is to save Xcel’s customers money, and this the shutdown would likely do, as dirty biomass burner “Power Purchase Agreements” are inflated in cost.
Since the burner has not been able to get enough “litter,” about one-half of what is burned is wood chips, and many comments opposing the shut down have come from logging interests and, disgracefully, from the Minnesota Department of Natural Resources.
So far as I can tell, none of the enviro types, energy wonk types, regulators, or elected officials who supported this damaging incinerator scam have chosen to publicly admit their mistake and support the shutdown.
You can read all the filings in the docket and file your own comments in a couple of ways:
(1) (less effective but easier) The PUC website has a “discussions” section but this has limitations including that dockets only appear here if they are officially open for public comment, and sometimes not even then. For example, the Benson burner docket is not there, although it should be. Search for docket “17” (year) and “530 (docket number).
(2) (more impactful) You can use the “edockets” system to read, download, or print the documents in any docket you are interested in. You can use the “efiling” system to file your own comments in the Benson 17-530 docket — the next round of comments is due September 15. To use efiling you need to sign up and get a password, but it’s not hard. If you file comments after the official closing of public comment, they may or may not be considered. For example, the Commissioner of the Department of Natural Resources recently filed out-of-time comments opposing the Benson shutdown–arguing on behalf of the DNR’s friends in the logging industry.
Here’s the notice with information on how to file comments in this Benson 17-530 docket:
The “Public” Utilities Commission is not supposed to be just an industry playpen, though too often it seems that way!
Here are the previous comments I submitted in favor of the shutdown:
Energy & Environmental Consulting
1110 West Avenue
Red Wing, MN, 55066
September 1, 2017
Daniel P. Wolf
Minnesota Public Utilities Commission
121 7th Place East, Suite 350
St. Paul, Minnesota 55101
Reply Comments: Petition of Xcel Energy to terminate a Power Purchase Agreement , etc. with Benson Power, LLC (Ex Fibrominn) E002/M-17-530
Dear Mr. Wolf:
I have been involved in controversies over poultry litter incineration projects instigated by Fibrominn and its successors for many year and in several states.
Such projects were rejected in various US states including Delaware, Maryland, Virginia, North Carolina, and Georgia. Thus, observers were puzzled that such a facility would be accepted in Minnesota. They especially were puzzled that “environmental” interests supported, or failed to oppose, the Benson proposal.
Opposition to poultry litter incineration projects has centered on high emissions, high costs, damage to public health and quality of life in host communities, and undesirable diversion of fiber and nutrients from field application to incineration. I note, for example, that so high are the Benson air emissions that a smokestack over 300 feet high was built to disperse these into the community. Only a fifty (or fifty-five) megawatt generator, “The permit granted for their Fibrominn project allows them to be Minnesota’s largest single source of arsenic pollution, their largest source of sulfuric acid air emissions, their 2nd largest source of hydrochloric acid air emissions, and a significant new source of dioxin pollution.” 1
The history of the Benson project has been characterized, as would be expected, and as was predicted by opponents, by high emissions, serious and ongoing violations of air permit limits, deceptive practices, and complaints from Benson residents of damage to their health and quality of life. See, for example, this stipulation agreement with the Pollution Control Agency: http://www.bredl.org/pdf2/FibrominnExecutedSTIP12-16-09.pdf
The Benson project has been unable to secure adequate amounts of poultry litter and has become largely a wood burner. Poultry litter, in general, is about fifty percent wood chips and fifty percent bird emissions. Thus, the Benson facility, burning, as has been stated, about one-half poultry litter and one-half wood chips is in fact burning about 75 percent wood.
Wood is a very dirty and chemically complex fuel, and nominal wood burners typically cause the same sorts of environmental problems as the Benson “litter” burner, while producing excessively expensive energy.
Xcel, in its Petition, notes a “plant heat rate of 14,250 Btu/kWh per Benson Power’s 2016 budget.” This corresponds to a thermal efficiency of twenty-four percent. The most efficient coal units have heat rates of around 9,000 Btu/kWh, corresponding to a thermal efficiency of around 38 percent, and combined cycle gas units are over 60 percent efficient.
Thus, I support the proposals of Xcel Energy to terminate power purchase agreements with various “biomass” burning facilities and to purchase and shut down the Benson burner.
(However, one must note the hypocrisy of Xcel in continuing to operate company-owned garbage incinerators in Red Wing, Mankato and French Island (La Crosse) that are similarly dirty and expensive. If Xcel was truly concerned about the well-being of its customers and the public at large it would shut these down and get out of the dirty-burner business entirely.)
(Also parenthetically, large Confined Animal Feeding Operations, including turkey barns, produce large concentrations of nutrients which pose problems. Thus, it is understandable that promoters of “magic bullet” solutions such as incineration have an audience. However, it seems well established that best practices for management of turkey litter should be based on properly managed—not to excess!) land application.)
A review of the filings in this docket indicates—unless I have missed them—no mention at all of the environmental merits, or lack thereof, of the Benson facility. Similarly there is very little mention of the merits of the facility as a power plant. It seems that all the important issues are missed or disregarded.
Unfortunately the actual cost of the Power Purchase Agreement is concealed as proprietary, although it is difficult to imagine any justification for this.
The proposal to pay off the City of Benson out of the proceeds of the “Renewable Development Fund” are yet another abuse of this every-scandalous fund, essentially none of which has ever been used as intended to compensate Red Wing and Monticello for Xcel’s nuclear plant/waste presence.
I conclude that the most important matters in this docket are yet unaddressed, and the comment period should be extended. Especially, it is scandalous that “environmental” interests, which initially promoted the agreement leading to the Benson facility, have not chosen to comment.
I also contemplate petitioning to intervene in this docket.
Yours very truly,
From: Alan Muller <firstname.lastname@example.org>
Subject: ADM air permit public notice
CC: Kathleen.Winters@state.mn.us, “Carol A. Overland” <email@example.com>, Ruth.firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, Anne Jacobson<email@example.com>
May 10, 20717
Industrial Division. Minnesota Pollution Control Agency
520 Lafayette Rd
St. Paul, MN 55155
Dear Mr. Timler:
I am a resident of Red Wing and am reviewing the:
“Public Notice of Intent to Modify Air Permit 04900001-101” dated May 4, 2017, for the subject ADM facility in Red Wing.
These are initial questions and comments:
Please provide a copy of the “Consent Decree” referenced in various places in the Technical Support Document.
The expiration date of the permit is February 28, 2011. I question the appropriateness of modifications to a long-expired permit. Can the MPCA provide assurances that the long-expired permit, as modified in the current action, would comply with all current State and Federal laws, regulations, rules, and agency guidance, and be adequately protective of the community?
The Technical Support Document (TSD), at page 1, states:
“The facility emits particulate matter (PM), particulate matter less than 10 microns in size (PM10), PM less than 2.5 microns in size (PM2.5), volatile organic compounds (VOC), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx) and hazardous air pollutants (HAPs). PM/PM10/PM2.5 emissions are emitted from the handling and processing of the seeds, the meal system, and the refinery. PM/PM10/PM2.5, SO2, CO, NOx, and VOC emissions are emitted from the boilers. Hexane emissions (which are both VOC and HAP emissions) are released from the hexane extraction and recovery systems. The facility is a major source under federal New Source Review (NSR), the federal Operating Permit Program (40 CFR pt. 70), and federal National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).”
Has any ambient or fenceline monitoring been conducted to ensure compliance with air quality standards?
Have the cumulative impacts of this facility and others in the area been evaluated?
Has a Health Impact Analysis of this facility every been conducted?
Some of the emissions from this may be allergens, soybean particulate, etc. Has this been evaluated for possible health and quality of life impacts?
The TSD also states at page one that:
“Due to the time-sensitive nature of this project, this amendment will be issued in stages. The first stage (Stage 1) of the issuance will include the NSR portion of the permit (construction authorization and Title I requirements) while the second and final stage (Stage 2) will include the Part 70 portion of the permit (operating and periodic monitoring requirements). This effectively allows the Permittee to complete the construction-portion of this project during EPA review. The second stage (facility operation) will be issued following EPA review.”
What makes this project “time sensitive” in the eyes of the MPCA?
I am concerned about the statement “allows the Permittee to complete the construction-portion of this project during EPA review.” Construction should not be allowed to commence, let alone be completed, until the permitting process has gone to conclusion. Does the MPCA consider the EPA review an insignificant formality?
Please provide the name and contact information for the Region 5 staff who will be/are reviewing this permit.
At page 88 of the TSD (as pages are counted by the PDF viewer) begins a long series of line items entitles “PTE [Potential to Emit] by subject item.” The column headings are not aligned, but there seem to be entries for “Unrestricted Potential” and “Limited Potential.” In a great many cases the “Limited Potential” is given as zero. Just to pick one example, at page 95, emissions of “particulate matter” (undefined?) from “Bins/Harvestore” are given as 279 tons/year (“unrestricted”) and 0 (zero) “limited.” Since few if any air pollution control measures or devices are 100 percent effective, all these zeros seem questionable to me, and need further explanation and/or correction.
Neither the Public Notice nor the Draft Permit nor the TDS contains any summary of the total emissions of the facility. (The large emissions of Hexane, for example). This fails, in my opinion, to give reasonable, good-faith notice to the public of why this permit action/this facility might be of interest from an air quality point of view.
In view of the issues raised by even my cursory review of the Public Notice, the Draft Permit, and the Technical Support Document, the public comment period may need to be extended, else a Public Information Meeting may be needed.
Yours very truly,
1110 West Avenue
Red Wing, MN, 55066
Energy & Environmental Consulting
Red Wing, MN
Port Penn, DE
To the editor:
I’m a lifelong Democrat, but have known times and places where many of the more capable and honorable elected officials were Republicans. Cooperation existed and progress was made. Today’s Republicans often seem more like a hate group than a responsible political party. Consider the agenda of the present Minnesota House and Senate leadership: They are attacking freedom of expression with bills designed to harass demonstrators. They seek to shut down environmental protections and take from the poor and give to the wealthy. Evil-minded, punitive and vindictive bills by the dozens … and all too often these are supported by DFL fellow-travellers.
There is of course no shortage of horrible bills in this session of the Minnesota Legislature. One especially repugnant item is described in the letter below, recently published in the Star-Tribune:
- “A pair of bills oozing their way through the Legislature are a giveaway to Xcel Energy:
- “ HF113 / SF85 would (1) authorize Xcel to build a new power plant without getting a Certificate of Need from the Public Utilities Commission; (2) require the PUC to make Xcel customers pay for it, and (3) establish a scheme for an inflated rate of return for the plant.
- “The point of a Certificate of Need is to ensure that ratepayers don’t pay for unjustified capital projects. For Xcel to use its political clout in this way suggests the company knows the project cannot be justified except to inflate its “rate base” and thereby its profits.
- “These bills are discreditable to all the legislators involved, but especially concerning is that one of the Senate authors, Mike Goggin, who represents my district (21), is an Xcel manager.
- “Sen. Goggin’s authorship of a bill so flagrantly benefiting his employer at the expense of his constituents should be considered an ethics violation.
- “Alan Muller, Red Wing, Minn.”
The plant in question is a combined-cycle natural gas plant Xcel says it wants to build at the site of the present three “SHERCO” coal units. It is very unlikely that such a project is needed or makes economic or environmental sense.
Contact info for Sen. Goggin:
Two of the Senate authors are DFLers:
John Hoffman, 651-296-4154
Dan Schoen, 651-297-8060, sen. firstname.lastname@example.org
Few probably expect much of the just-starting-up 90th session of the Minnesota Legislature, and this will tend to be blamed on the Governor being a Democrat while the House and Senate are both controlled by Republicans. There will be, of course, some truth in this. But how much? Continue Reading →
[Note: I’m fortunate enough to have four of the nine reactors mentioned here in my life: Salem I and II, on the Delaware River between Delaware and New Jersey, and Prairie Island I and II, on the Mississippi River between Minnesota and Wisconsin. The details vary, but the essentials are similar. Not the least of the similarities is the revolting suck-up behavior of so many officials and organizations in “company towns.” In any case I wrote two versions of this post, focused on Delaware and Minnesota respectively. Below is the Minnesota version.]
The Prairie Island reactors (photo credit justchangelaw.com)
Areva SA, a French vendor of nuclear power plant equipment–one of the largest and most prominent in the world–has been found to be producing defective items–really major items!– and falsifying quality control paperwork. This means that reactors may be running in dangerously unsafe condition. French regulators appear to be acting, but US regulators are not. Continue Reading →
In these frightful times, good news is hard to come by. Here is some:
After a great deal of work, advocates in Winona County have passed a true ban on new frac sand mining. Here’s the story from the Frac Sand Sentinel:
RELEASE: In Historic Vote, Winona County Board Passes Ban on Frac Sand Operations
New Measure is First Known Countywide Frac Sand Ban
WINONA, Minn. — The Winona County Board of Commissioners voted tonight to pass a ban on any new frac sand mining, processing, storage or transport operations in the southeastern Minnesota county’s jurisdiction. This step comes after a 17-month grassroots organizing campaign by county residents calling for a ban, led by members of the Land Stewardship Project (LSP).
Continue Reading →
(Note: Slightly updated October 13th)
Or: Xcel Energy out of control.
In the context of electric and gas utility planning IRP means a plan for where our energy services are going to come from over some future time period. Note the word “services.”
Typically, if we want some increment of electricity services—heat, light, motor power, whatever, we can get it by generating it; this is called the “supply side.”
Or, we can get it by using what we have more efficiently. We can invest in more efficient lights, motors, or data centers. This is called the “demand side,” or “demand side management.” Continue Reading →
My comments as they appear in the transcript:
Mr. Allen Muller. My name is Alan Muller. I had a small environmental NGO and I have residences in
Red Wing, Minnesota, and Port Penn, Delaware, and from both of those locations, I can look out my
office window and see reactors.
I want to share with you the thought before I ask my question that with all due respect to the very
accomplished people on this panel, none of them in my view represent my interests. And the only way
that my interests are being injected into this discussion is through people having the gumption to stand up
and say things that you don’t want them to say, and you don’t want them to be talking. So that’s my
comment to you on the format of the meeting.
I read this consent-based siting report that the Blue Ribbon Commission put out a couple of years ago,
and I asked myself is it possible to imagine that a truly informed community in which the local officials
have not had their integrity and independence suborned – that is fully informed – would actually consent
to a nuclear waste storage facility? And I’m not able to imagine that. And having thought about it for a
couple of years, and listened to you folks for the last two hours, I’m still unable to imagine it.
So if anyone would care to comment on just what could you say that would give some assurance that a
community – an informed community, an independent community – a community that hasn’t been paid
off, actually would consent to host a radioactive waste management facility? Okay, that’s my question.
Mr. Jim Hamilton. Thank you for that.
Allen [no surname provided]. It seems to me that whenever a delegation from DOE or the Nuclear
Regulatory Commission shows up in Minnesota for some kind of evolution or event, the people are very
courteous; very bright; very gracious; very patient in the face of strongly worded criticism and so on.
But somehow it always has a feel to me that the nuclear industry is the dog and the tail is being wagged
by the dog [and the tail] is the federal entities that are supposed to be representing the public interest. And
that kind of bothers me. It would be – and I’m kind of repeating what other people have said – but it
would be very useful and helpful to have a DOE delegation show up and present a program for the rapid
phase-out of the civilian nuclear industry. It would be very nice to see like a rational program for the
replacement of that capacity as it’s shut down, rather than just totally passive reports from EIA saying that
the future is going to be the same as the past.
And nuclear waste management is a very complex issue. It’s complex economically; it’s complex
technically; it’s complex politically; it’s complex emotionally – it appears to be so complex on so many
levels that it’s insoluble. And I don’t know whether it has to be insoluble, but I would like to see a
proposal for solving this problem. For getting this waste somewhere where it eventually would be less
dangerous and less harmful than it is now sitting around in pools and waste cask parking lots.
Rather than coming to us suggesting that we ought to help you develop a program to get communities to
consent to the siting of facilities that are not in any obvious way part of any rational program for
managing the issue, just isn’t very satisfactory. I think you can and should do better than that.
Note: I sent this as an email yesterday. The election results:
Natalie Hudson prevailed with 65 percent of the vote. Michelle MacDonald received 20 percent and Craig Foss 15 percent.
Howe got 14 percent of the vote compared to 49 percent for Jason Lewis. So the upcoming general election will be Angie Craig vs Jason Lewis.
- Minnesota: A wholly owned subsidiary of Xcel Energy? #1 in a series. February 17, 2016
- Garbage prospers in the Minnesota Legislature March 12, 2015
- Reminder: TODAY – Greenhouse gas hearing Thursday, August 30th, 2:00, at the MPCA August 30, 2012
- RED ALERT: oppose mega-horrible utility deregulation bills March 18, 2015
- [Wash Post] “Utilities wage campaign against rooftop solar” March 9, 2015
- Comments due Sept 15th: Support shut-down of polluting, resource-destroying incinerator in Benson, MN. September 12, 2017
- Letter to MN officials about ADM Red Wing air permit May 10, 2017
- Letter: ‘Our’ legislators agenda is beyond shameful March 16, 2017
- Action Alert: Another inexcusable giveaway to Xcel Energy February 8, 2017
- Who really runs the Minnesota Legislature? January 11, 2017
- alan: Thanks for the comment. I view CEE as essential...
- John: Wholesale prices down, retail prices up, equals Xc...
- TONY NELSON: I noticed you painted all the participants with a ...
- “Areva” nuclear scandal casts doubt on the safety of the Prairie Island I and II reactors | alanmuller.com: […] Minnesota: A wholly owned subsidiary of ...
- Alan Muller: I did not know that, but would not be surprised. ...
- Comments due Sept 15th: Support shut-down of polluting, resource-destroying incinerator in Benson, MN.
- Letter to MN officials about ADM Red Wing air permit
- Letter: ‘Our’ legislators agenda is beyond shameful
- Action Alert: Another inexcusable giveaway to Xcel Energy
- Who really runs the Minnesota Legislature?
- "Environmental Legacy"
- "Streamlining" and "Improvement"
- air pollution
- air pollution alert
- Childrens' Health
- City of Red Wing
- City of Red Wing (Minnesota)
- climate change
- coal ash
- Community Solar Gardens
- Covanta/Hennepin County "Environmental Services"
- Environmental Justice
- Environmental Protection Agency (EPA)
- Environmental Quality Board
- Environmental Regulation–Protecting Minnesota
- Frac sand mining
- Garbage Incineration
- General Mills
- Goodhue County
- Gov. Dayton's Executive Orders
- Liquified Natural Gas
- Metallic Mining
- Minnesota energy policy
- Minnesota Legislature
- Minnesota Pollution Control Agency
- Minnesota Power
- MN Public Utilities Commission
- MPCA Citizens' Board
- Nuclear Power
- Nuclear Regulatory Commission
- plants and animals
- St. Paul
- Union Pacific
- water pollution
- Xcel Energy