SLC VISUAL CHANGES RAISE ADDED HEALTH CONCERNS
Latest company spin on visuals is contradicted by its own statements on emissions controls
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HUDSON -- In proposing what it claims are visual improvements to its vast, coal-fired plant design, St. Lawrence Cement may have introduced as many new problems as it hoped to put to rest -- most troublingly, pollution and health issues.
For example, one of means put forth by SLC to reduce its stack height is to remove one of five stages in the preheater-precalciner kiln. But earlier statements by key St. Lawrence Cement officials and consultants have called into question the wisdom of that approach.
During the NYS Dept. of Environmental Conservation's "issues conference" for SLC in July-August 2201, the company raised strenuous objections to the notion of removing a stage from the stack in order to reduce its height -- the same idea it proposed today.
Then-project manager and engineer Phil Lochbrunner stated at the July 27, 2001 hearing before administrative law judges Helene Goldberger and Maria Villa that reducing the number of stages would result in more coal and water consumption, and greater pollution impacts:
"Reducing the number of stages reduces the amount of heat that is transferred. The consequence of this is that additional fuel must be consumed to replace the heat that is lost, or allowed to escape from the system. This carries with it the consequence of increased NOx and CO emissions. ... For the Greenport tower, removing one stage would result in approximately a 15 meter, or roughly 48 foot reduction in height. Removing the top stage would result in an increase in fuel consumption of approximately 6.2 percent, an increase in NOx emissions of 6.3 percent, and an increase in CO emissions of 6.5 percent."(SLC Issues Conference transcript, Vol. 8, pp. 1575-6)
Similarly, St. Lawrence lead attorney Thomas West agreed with Lochbrunner that:
"The simple fact of the matter is we can't make the preheater tower smaller. To do so would be at a significant energy and environmental penalty, neither one of which is tolerable, and it means that that design alternative is not feasible." (Transcript, p. 1591)
"We would applaud a good-faith effort from SLC to incorporate meaningful changes to the Greenport design, especially on pollution controls,"commented Friends of Hudson executive director Sam Pratt.
"Unfortunately, according to the company's own past statements, the ideas put forth today raise as many problems as they seek to resolve. What SLC has proposed may actually be a step backward from a health standpoint."
The company also dodged questions about whether a lower stack would result in more pollution falling on the local community, rather than being dispersed downwind. Denise [Brubaker] Ryan's admission today that wind turbulence would be different with a lower stack height only points up our longstanding argument that the company needs to finally use the local wind data it collected in Greenport, rather than Albany data," Pratt added.
Over the history of this project review, intervenors including Friends of Hudson, the Hudson Valley Preservation Coalition, Natural Resources Defense Council, The Olana Partnership and The Preservation League of New York State have each argued that the company had failed to perform an adequate analysis of alternative plant configurations. These have included suggestions regarding the scale, technology, location, noise, traffic and other impacts from such a massive facility--all summarily rejected by St. Lawrence.
SLC's event today ignored all of the substantive pollution-control measures put forth by major engineering firms, including solutions endorsed by regulators at neighboring Departments of Environmental Protection in Massachusetts and Connecticut. Friends of Hudson has proposed the use of gas instead of coal; a regenerative thermal oxidizer (RTO) to combat volatile organics; and selective catalytic reduction (SCR) to address nitrogen oxides. Each has been rejected by SLC.
Indeed, past company rhetoric has belligerently rejected the notion that any further changes could be made to the Greenport project design.
For example, during the 2001 issues conference, Friends attorney Jeff Baker noted that "No alternative visual analysis is being presented. We don't have an alternative design for a plant, either in Greenport or Catskill." (Issues Conference transcript, p. 360). To Baker's call for a trial to explore such alternatives, SLC's Tom West insisted that:
"There is no omissions [sic] in the application materials to evaluate alternatives. ... The current application has already a complete record on alternatives." (p. 357)
"We stand on the completeness of the alternatives analysis. We believe that your request for further information is a classic completeness issue that is not adjudicable." (p. 370)
"The applicant has comprehensively addressed all feasible and reasonable alternatives." (p. 1555)
For Friends of Hudson, which began challenging the SLC proposal in 1999, today's press conference "was like deja vu all over again," said Pratt. "The company held a virtually identical press conference on October 13th, 1999, moving the stack from Route 9 to the quarry. Like today, it said five years ago that the plant would become almost invisible. Five years later, opponents succeeded in its efforts to force a new balloon test, and the truth came out. Given that experience, today's new claims need to be subjected to the highest levels of scrutiny."
TRANSCRIPT: PHIL LOCHBRUNNER OF SLC, JULY 27, 2004 (ISSUES CONFERENCE, HUDSON, NY) • Pages 1575-77
PHIL LOCHBRUNNER, ST. LAWRENCE CEMENT:
"The Greenport preheater/precalciner consists of five stages. This means that it consists of a string of the five of the aforementioned cyclones arranged in series. The fuel efficiency of a preheater is directly related to the number of stages. The feed and hot gasses intermix in these, stages transferring the heat from the gas to the feed.
"Reducing the number of stages reduces the amount of heat that is transferred. The consequence of this is that additional fuel must be consumed to replace the heat that is lost, or allowed to escape from the system. This carries with it the consequence of increased NOx and CO emissions.
"The purpose for this discussion is that the only effective means of reducing preheater tower height would be to reduce the number of stages. For the Greenport tower, removing one stage would result in approximately a 15 meter, or roughly 48 foot reduction in height.
"Removing the top stage would result in an increase in fuel consumption of approximately 6.2 percent, an increase in NOx emissions of 6.3 percent, and an increase in CO emissions of 6.5 percent. Removing two stages would result in a decrease in height of approximately 30 meters or roughly 96 feet, would also result in an increase of fuel consumption of 18 percent, and increase in NOx emissions of 17.7 percent, and an increase in CO emissions of 19.6 percent.
"As you may note, there is a diminishing return as stages are added due to the steadily decreasing temperatures of the gas stream. That has the effect of reducing the heat transfer potential. We actually looked at the possibility of a six stage preheater, and it could potentially be used with the Greenport raw material, but came to the conclusion that the additional 15 meters or 48 feet in height would not be acceptable and would not offset the slight changes in--positive changes in fuel consumption.
"In addition, there are other consequences to increasing the fuel consumption as well. More water will be required for cooling the gas stream prior to the pollution control equipment and in the scrubber. This would result in increased occurrences of a steam plume, which we have worked very hard to minimize. In addition, the increased fuel consumption would result in one or two or maybe more ship loads of coal being loaded at the dock and conveyed out to the plant."