Comment on the air permit for the proposed PTT Global ethane cracker, which would become part of the proposed massive Appalachian Storage Hub/Petrochemical Complex in the Ohio River Valley. This cracker plant, while in Ohio, has the potential of impacting air quality for Moundsville and Wheeling, WV. 

Written comments must be received by Ohio EPA/Southeast District Office by 5 p.m. December 11, 2018. Comments received after December 11, 2018 may not be considered to be a part of the official record.

You can view the permit here.

Want some inspiration for you comments? Read this: Quality of our region’s air remains an issue

In addition, here are some points for comments:

About the project

• PTT Global Chemical, a Thailand-based company, along with Daelim Chemical and China Energy are planning to build a massive petrochemical plastic plant alongside the Ohio River in Belmont County.
• The facility will contain at least one ethane cracker, a type of petrochemical plant that takes fracked ethane gas and “cracks” it into ethylene – the feedstock for single use plastics.
• It is estimated the plant will have the capability of producing up to 1.5 million metric tonnes of ethylene per year, costing up to $10 billion when completed.

This project will produce “feedstock” for single use plastics

• Petrochemical plants like this one are an important part of the industry’s goal to increase global plastic production by 40 percent by 2030.
• Starting a hub of dirty, dangerous plastic production in Ohio and surrounding states will harm local communities with toxic pollution and contribute to the growing global plastic pollution crisis.
• The PTTGC project will create more unneeded plastic, which is the most common type of marine pollution. Plastic is already expected to outweigh all the fish in the world’s oceans by 2050.
• This project will contribute to the region’s reliance on fracking, offering incentive for other global plastic companies to come into our communities and build more ethane crackers.

The next ‘Cancer Alley’

• This project is slated to be one of the largest petrochemical plants in the U.S., satisfying industry’s desires to transform the Rust Belt into the next petrochemical hub in the Appalachian Ohio River Valley.
• The Ohio River is a drinking water source for over five million people and prone to flooding. Another polluting plant along the river will lead more pollution and increasingly worse floods.
• The topography of the Ohio River Valley is known to trap air pollution because of the surrounding steep hills. The nearby communities do not deserve to bear this environmental burden of these toxic emissions, just for industry to profit.
• Application numbers show the project will dump up to 3½ school bus loads of fine particles into the Shadyside community. Petrochemical particles can accumulate in human tissues and organs such as the brain and liver and can cause brain, nerve and liver damage, birth defects, cancer, asthma, hormonal disorders, and allergies.

PTTG’s air application is incomplete

• The cumulative impact of a petrochemical facility and the associated greenhouse gas emissions that will come with it are not being properly assessed by PTTG’s application.
• No health risk assessment has been completed, nor are there plans to do one, despite this project being a major public health issue.
• The PTTG ethane cracker air permit should not be issued until a rigorous assessment of current health impacts from fracked gas production in Belmont County has been conducted.

Some examples of deficiencies found in the PTT Global Ethane Cracker Plant Draft Air Permit Issued by Ohio Environmental Protection Agency

• No health risk assessment has been done, nor are there plans to do one, despite this being the clearest way to determine the impact of the facility to public health
• Some of the air pollutants expected to be emitted from the facility that are known to negatively impact human health include particulate matter (PM [120 tons per year], PM 10 [89 tpy], PM2.5 [86 tpy]), Nitrous Oxides (164 tpy), and air toxics (VOCs)(396 tpy).
• The facility is also expected to emit 1,785,043 tons per year of CO2 or CO2 equivalents.
• The draft permit identifies “proper design,” “good combustion practices,” and “good operating practices” as the emissions control technology for most of these emissions, without setting any specific requirements.
• The PTTG’s air permit application only assessed those air toxics that it anticipates emitting in excess of 1 ton per year. This is not a health-based (or science-based) threshold for determining the impact of toxic air contaminants.  A health impact assessment would be the proper way of doing that. 
• Air toxics PTTG expects to emit in excess of 1 ton per year include hexane, ammonia, and ethyl chloride. There are numerous other toxic air contaminants that the facility will be emitting that were not assessed.
• The proposed monitoring scheme for emissions from much of the facility is weak, relying on calculations and sporadic testing, with continuous monitoring in place only for NOx, CO2, and O2.
• The draft permit requires an unusually low control efficiency for emissions from the cracking furnaces (the primary source of the plant’s combustion emissions), the draft permit requires they only have 90% control efficiency – this is significantly lower than what is typically required by air permits.
• No fenceline monitoring is required, despite that being a known available and effective way to keep track of what is entering the surrounding community, and despite fenceline monitoring being implemented for the Beaver plant (as the result of litigation).
• All air modeling in PTTG’s application is based on meteorological data from the Buckeye Cardinal Power Plant, 46 miles north, not data from the actual site.
• Nothing in Ohio EPA’s review process appears to account for the fact that the PTTG facility is intended to increase oil and gas development and petrochemical development in the region, as well as plastics production, all of which will come with their own emissions of air contaminants of concern. In short, the cumulative impact of the petrohub on the Ohio River Valley’s air is not being assessed by OEPA or USEPA, nor is the cumulative contribution of GHGs.
• The plant is to be located on top of the old R.E. Burger Power Plant site, which had significant environmental contamination issues that were allegedly addressed through Ohio EPA’s Voluntary Action Program, which means very little is known about what cleanup actually took place. Construction on that site could place groundwater at risk.  The public needs to know more about what type of remediation was done.

From the Ohio EPA Notice Info:  This facility will generate emissions including carbon monoxide (CO), nitrogen oxide (NOx), volatile organic compounds (VOC), small sized particulate matter (PM10/PM2.5), and greenhouse gases (GHG).

 

Further information concerning this application, which is available for public inspection, may be secured from Kimbra Reinbold, Ohio EPA DAPC, SEDO at the above address during normal business hours. Telephone number: (740) 380-5245.

The permit and complete instructions for requesting information or submitting comments may be obtained at: http://epa.ohio.gov/dapc/permitsonline.aspx by entering the ID # or: Kimbra Reinbold, Ohio EPA DAPC, Southeast District Office, 2195 Front St., Logan, OH 43138. Ph: (740)385-8501. The public comment period will run until 12/03/2018 at 05:00 PM.