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Letter to MN officials about ADM Red Wing air permit

To:         jacobe.timler@state.mn.us

From:    Alan Muller <amuller@dca.net>

Subject: ADM air permit public notice

CC:         Kathleen.Winters@state.mn.us, “Carol A. Overland” <overland@legalectric.org>, Ruth.greenslade@co.goodhue.mn.us, john.stine@state.mn.us, ed.ehlinger@state.mn.us, Anne     Jacobson<ajacobson@republican-eagle.com>


May 10, 20717

Jacobe Timler
Industrial Division. Minnesota Pollution Control Agency
520 Lafayette Rd
St. Paul, MN 55155
Phone: 651-757-2410
Email: jacobe.timler@state.mn.us

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,

Alan Muller
1110 West Avenue
Red Wing, MN, 55066

Alan Muller
Energy & Environmental Consulting
Red Wing, MN
Port Penn, DE
302.299.6783
alan@greendel.org

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Letter: ‘Our’ legislators agenda is beyond shameful

[Published March 15,2017 in the Red Wing Republican Eagle]

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.

Continue Reading →

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Action Alert: Another inexcusable giveaway to Xcel Energy

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:

651.296-5612
https://www.senate.mn/members/member_emailform.php?mem_id=1226&ls=90

Two of the Senate authors are DFLers:

John Hoffman, 651-296-4154
https://www.senate.mn/members/member_emailform.php?mem_id=1205&ls=90

Dan Schoen, 651-297-8060, sen. dan.schoen@senate.mn

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Who really runs the Minnesota Legislature?

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 →

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“Areva” nuclear scandal casts doubt on the safety of the Prairie Island I and II reactors

[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.]

http://justchangelaw.com/wp-content/uploads/2012/11/16452401_BG1.jpeg

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 →

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Rare good news–Winona County passes frac sand mining ban

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

11/22/16

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 →

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“Integrated Resource Planning” and why doesn’t Minnesota have it?

(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 →

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Do nuclear waste dumps again threaten Minnesota?

the US Department of Energy is working on a scheme to get communities to “consent” to hosting nuclear (spent fuel) waste dumps.  (Yucca Mountain being dead, they want to find other locations.)  Northern Minnesota has in the past been a target for nuke waste dumping, and could be so again.  DOE held a “public meeting” in Minneapolis on July 21st.  Carol and I attended.  Video and transcript are here.  John Tuma, a member of the Minnesota Public Utilities Commission, was the keynote speaker.

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.
[Applause].
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.
51
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.

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Aug 9th Primary: Howe and Hudson

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.

Continue Reading →

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Bad air–conditions unfavorable to human comfort and health prevail in Minnesota

The national weather service has issued an “excessive heat warning” until 1900 Friday.

* temperatures: highs well into the 90s this afternoon and lows
  tonight in the mid 70s.

* Dew points: mid 70s to lower 80s.

* Heat indices: 105 to 115 degrees.

* Impacts: a heightened risk of heat related illness...  
  especially for those active outdoors or for those without air 
  conditioning. 

Precautionary/preparedness actions... 

Take extra precautions... if you work or spend time outside. When
possible... reschedule strenuous activities to early morning or
evening. Know the signs and symptoms of heat exhaustion and heat
stroke. Wear light weight and loose fitting clothing when
possible and drink plenty of water.

To reduce risk during outdoor work... the occupational safety and
health administration recommends scheduling frequent rest breaks
in shaded or air conditioned environments. Anyone overcome by
heat should be moved to a cool and shaded location. Heat stroke
is an emergency... call 9 1 1.

An excessive heat warning means that a prolonged period of
dangerously hot temperatures will occur. The combination of hot
temperatures and high humidity will combine to create a dangerous
situation in which heat illnesses are likely. Drink plenty of
fluids... stay in an air-conditioned room... stay out of the sun... 
and check up on relatives and neighbors.


        ******************************

In addition to this:

******************************
The Minnesota Pollution Control Agency (MPCA) is issuing an air pollution health advisory for portions of eastern Minnesota, effective Thursday, July 21 from 11 a.m. through 9 p.m.. The affected area includes the Twin Cities Metro north and east to Cambridge, North Branch, Forest Lake and Stillwater.

[Friday is an air quality *alert* day due to forecasts of Code Orange conditions.]
Air quality is expected to deteriorate over the next two days.  Sunny skies, hot temperatures, and light winds will combine to cause an increase in ground-level ozone.  Air Quality Index (AQI) values are expected to climb into the 90s on Thursday in the advisory area, which is approaching air quality conditions considered unhealthy for sensitive groups. Ozone concentrations will be the lowest in the morning hours Thursday, and will gradually rise midday through the afternoon. Air quality will improve overnight before worsening again on Friday, with additional advisories and alerts possible.

At-risk Populations: Ozone pollution is expected to be near a level considered unhealthy for sensitive groups. Those sensitive to ozone include people with preexisting respiratory or cardiovascular conditions, the elderly, children, and individuals who participate in outdoor activities requiring extended or heavy exertion. These individuals are encouraged to postpone or reduce vigorous outdoor activity, or schedule outdoor activity in the morning, when ozone levels are lower. Even persons who are otherwise healthy may experience health effects when ozone levels increase.

Health Impacts: Elevated levels of ozone have been linked to respiratory and cardiovascular health effects. Exposure to high levels of ozone may exacerbate preexisting health conditions. High ozone levels may make it more difficult to breathe deeply and vigorously, cause shortness of breath and breathing discomfort, and result in coughing and a sore or scratchy throat. If you experience these symptoms, contact your physician.

Pollution-reduction Tips: Ozone is produced on hot, sunny days by a chemical reaction between volatile organic compounds and oxides of nitrogen. These pollutants are released from motor vehicles, lawn and garden equipment, paints and solvents, refueling stations, and other activities that require fuel combustion. Conserving energy; buying clean, renewable power; and utilizing alternative means of transportation, such as mass transit, will all reduce your contribution to air pollution. During air quality alerts, residents are particularly encouraged to use public transportation, car pool or reduce vehicle trips and engine idling. Postpone the use of gasoline-powered equipment and avoid burning wood.

 Visit http://www.pca.state.mn.us/aqi for information on current air quality conditions in your area. To receive daily air quality forecasts and air quality alert notifications by email or text message sign up at http://mn.enviroflash.info. You can find additional information on indoor and outdoor air quality in Minnesota at www.beairawaremn.org
Do not reply directly to this email. If you want more information on the air quality forecast, or other aspects of the local air quality program, please contact your local air quality agency using the information above. For more information on the U.S. EPA’s AIRNow Program, visit http://www.airnow.gov.

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The air quality forecast for the Twin Cities (the MPCA issues forecasts only for the Twin Cities and Rochester but conditions are often equally bad elsewhere in Minnesota) are:

Thursday:  Code Yellow

Friday: Code Orange  (I would call this Code Red as there is a Code Yellow forecast for particles in addition to the Code Orange forecast for Ozone.

Saturday:  Code Yellow.

In addition to this, Pollen.com is forecasting “medium” levels of allergens for the next few days. (https://www.pollen.com/forecast/extended/pollen/55401).

The cumulative effects of bad air quality, high temperature and humidity, and allergens have very serious health impacts.  Please take care and try to make sure that vulnerable people have access to air conditioned spaces.

The causes of bad air in Minnesota are, obviously, complex.  Simple answers are lacking.  But many of our problems are self-inflicted.   Scandalously, the “Pollution Control” Agency (1) actively campaigns to increase garbage incinerator pollutants, (2) has allowed the majority of air permits in Minnesota expire, and (3) has hired “Environmental Initiative” (an org beneath contempt) to run a campaign to prevent the EPA from designating Minnesota from being in “non-attainment” of air quality standards.  Shame, shame, and more shame.

Alan Muller

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