By: Lydia Crawley
The Parsons Advocate
The West Virginia Department of Environmental Protection Air Quality Board heard testimony Wednesday and Thursday December 3rd and 4th from Independent Consultant Dr. Ranajit “Ron” Sahu on the Ridgeline Power Plant appeal filed jointly by Tucker United, the West Virginia Highlands Conservancy and the Sierra Club.
Dr, Sahu, a graduate of the California Institute of Technology or Caltech, in Pasadena, holds a PhD in Combustion and has degrees in the power plant and emissions fields going back to 1983. His PhD focus was on air pollution and he has worked with various Federal, State, NGO, environmental and private organizations as a consultant, as well as has an extensive history as a professor as various colleges across California. He has worked as a Professor, Designer and Consultant. Specifically, he has been a Consultant since 2000.
Dr. Sahu was offered as an expert by the appellees as an expert on exactly what could and could not be derived from the redacted permit. Dr. Sahu said he had closely studied the application and the permit and was troubled by what he saw.
“Off to the right is the 98.89 tons of NOX which I think, as prior testimony has elicited, is literally a shade below the 100 ton for your major source threshold and I have concerns about verification of that,” Dr. Sahu said.
Dr. Sahu spoke on the redactions in the tables of the application. He said there was no knowledge of the number of turbines or the start-ups or shut downs. Emissions were also an issue with the redactions.
Dr. Sahu explained extensively about how start-ups and shut downs can affect emissions of a plant. Dr. Sahu said that incomplete combustion will produce higher levels of pollutants and were calculations that did not seem to be addressed by the documents. Dr. Sahu testified that double the pollutants were released during start-ups and shut-downs during the 10 to 15 minute period it took to complete the cycle. Dr. Sahu said in some cases, it could even take up to an hour.
One of the largest questions that seemed to keep being circled back around to was the question of monitoring and how it could be known if the plant was exceeding their “synthetic minor” limitations. Dr. Sahu said under the current plan, there was no provision for continuous monitoring.
“Well, the short answer is, you cannot and that’s the whole problem with the permit,” Dr. Sahu said.
Dr. Sahu said that monitoring was not a matter of arithmetic. It could not be factored by equations. Dr. Sahu said that equations and arithmetic did not factor for everyday factors such as the shut-downs and start ups or other less controllable factors such as air, ambient conditions, temperature, relative humidity and equipment age. He said there was no way to know exactly what kind of pollutants were being produced from the redacted documents. The only information was on NOX and CO. There was no information on other pollutants such as formaldehyde, nitrous oxide, carbon monoxide and particulate matter.
Dr. Sahu said even the type of fuel can effect the production of pollutants. In the case of natural gas, he said that there was a large range of composition from methane content to ethane, propane, butane and butylenes. The same thing is true of diesel, he said with viscosity among other significant changes being a factor in pollution production.
“And you have to look at all of that before you can simply say, ‘Hey, I’m a shade below 100 tons for NOX or below 10 tons for formaldehyde’ and call it a day just by tracking hours,” Dr. Sahu said.
Dr. Sahu said that even using the redacted information, the permit would be a Major Source. He also said that even if using either fuel natural gas or diesel alone, would make no difference, it would still be a major source. When figuring for formaldehyde emissions from diesel fuel use, Dr. Sahu said the following:
“And by including a reasonable estimate, even from the redacted version, forward those missing start-up/shut-down emissions are for formaldehyde, I am well over 10 tons,” Dr. Sahu said. “I am at 23.6 tons.”
Dr. Sahu claimed that the plant would be over the 10 ton limit for formaldehyde for a Synthetic Minor Permit, regardless the fuel used. He said no matter the fuel used, the plant would be a Major Source emitter.
“On either fuel alone, will be over and of course, combine both fuels, you’re over,” Dr. Sahu said.
