E-M:/ Toledo Coke/coal permit

OEPA ISSUE FDS COKE PLANT PERMIT 1-31-08

The 2.2 million ton coal fired coke plant OEPA second modified permit was issued Jan. 31, 2008. The initial permit was issued June 14, 2004, modified in 2005 and now again in 2008. With a growing awareness of how bad coal is for the air and a growing awareness of the impacts of mercury on human health and fish, OEPA is once again reducing the requirements to control mercury. OEPA is allowing 2 lbs of carbon injection instead of the 10 lbs in the 2004 and 2005 permits and even then is not certain how much mercury will be emitted.

Furthermore, OEPA has elected to ignore the 1.1 million tons of CO2 green house emissions that this facility will give off.

For those locally that have been told this plant is much better than the old - OEPA states that the old coke plant used 166,645 tons of coal and the new one will use 2,058,600 tons of coal(OEPA Response 16). OEPA admits that some pollutants may be higher than the old coke plant. The numbers show overall emissions will be three times as great as the old coke plant with increases in S02, CO, NO. and fine and other particulates.

Here is OEPA's statement on mercury in the FDS permit: "The plant is proposed to be built on land in east Toledo and Oregon. The plant would produce 1.44 million tons of coke per year from 168 ovens configured in two batteries. The permit requires FDS to use state-of-the-art technology to control mercury emissions. Ohio EPA analyzed the anticipated mercury emissions and compared them to state and federal guidelines that are protective for acute (one-hour) or chronic (lifetime) exposure to mercury. The mercury limits in this permit are well below those that would cause health effects (less than one percent of the safe levels).

The permit allows FDS to bypass pollution control equipment up to eight days a year for inspections and maintenance. FDS must control at least 90 percent of the mercury produced and emit no more than 51 pounds of mercury per year. However, because the carbon injection control device to be used has not been tested on coking plants, the achievable control efficiency is uncertain. Therefore, Ohio EPA added language to the permit that allows FDS to request the mercury control efficiency and emission limit requirements be adjusted after the control system has been installed and optimized. These limits can be adjusted if it is shown that the equipment is operating as designed and the amount of mercury emitted will be protective of public health. Ohio EPA believes these limits are protective of public health and the environment.

For additional information:

OEPA FDS 1-31-08 Permit:

http://www.epa.state.oh.us/dapc/pti_issued/pti_pdf_08/0401360fm2.pdf.

OEPA FDS Draft Permit:

http://www.epa.state.oh.us/pic/fds.html.

FDS Application

http://www.epa.state.oh.us/dapc/transfer/USCokingCorp.pdf.

OEPA response to public comment:

http://www.epa.state.oh.us/dapc/transfer/FDSCokeResponseComments013108.pdf.

OEPA Cooling Tower Power permit

http://www.epa.state.oh.us/dapc/pti_issued/pti_pdf_08/0401490f.pdf.