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GLIN==> Liberty Renewable Fuels -- Out of Great Lakes basin groundwater transfer and greenhouse gas emissions



What are the groundwater, Great Lakes water transfer and greenhouse gas
consequences of the Granholm drive to benefit
corn growers through promoting the construction
of ethanol plants in Michigan?  

We?re now beginning to find that out ? these facilities
will be large air dischargers (including greenhouse gases)
and large groundwater mining operations that will
make the water bottling plant issue look small in
comparison.....and with Great Lakes watershed diversion consequences.

On January 29, Michigan DEQ will hold a public
meeting and public hearing on a proposed air permit
to install for LIBERTY RENEWABLE FUELS
which is proposed for siting at Ithaca, MI, right
next to US-127.

The meeting begins at 6 PM and the public hearing
at 7 PM.  It will be at the Ithaca Community Center,
120 North Maple Street, Ithaca.

Public participation documents are at (scroll down):

http://www.deq.state.mi.us/aps/cwerp.shtml

Neither Republican nor Democratic gubernatorial
administrations have fixed Michigan?s severe problem
of not having a comprehensive environmental
review process for such major state decisions as
permitting one of the largest ethanol production
plants in the entire midwest.   This means that issues
such as greenhouse gases and water mining
as environmental impacts never get considered.  This
includes the out of Great Lakes basin transfer
consequences of this proposed ethanol plant.


Liberty Renewable Fuels Groundwater
Mining and Out of Great Lakes Basin Transfers

Preliminary indications found in MDEQ files are
showing that Liberty Renewable Fuels is planning on
using 1200 gallons per minute of groundwater derived
from three on-site 12 inch wells drilled 400 feet deep.

That is a potential consumption of 630 MILLION
GALLONS PER YEAR OF GROUNDWATER. 

To the best of my knowledge there will be no review
and impact analysis of the consequences of this
groundwater consumption on area wells, water table and
out-of-Great-Lakes-basin transfers through air discharge
from evaporation and steam discharges.

Out of the 630 million gallons per year, at least 47 million
gallons/year on the average will be discharged to the air
as evaporated process water assuming
100% of the spent grain waste from the plant is dried.  

If this plant is like other ethanol plants, about 193 million
gallons per year will be lost to evaporation from plant site
cooling towers.   Other process and steam discharges of
groundwater might be as much as another 100 million
gallons per year.  

So, about half of the groundwater that Liberty Renewable
Fuels will be mining in Ithaca or about 340 million gallons
per year will be evaporative losses and
thus out of Great Lakes basin transfers.   Liberty Renewable
Fuels could cut their groundwater use by using dry cooling
processes, but they are not proposing such methods.

The rest of the water will be discharged to surface water
as cooling tower blowdown and reverse osmosis filter
backwash.   Cooling tower blowdown is likely to contain
significant toxicity from use of algicides and treatment
chemicals.   The reverse osmosis filter backwash wastewater
will contain any toxicants found in the groundwater, but at
much higher concentrations.  In a review of chronic toxicity
of such wastewater at an Iowa plant, 100% undiluted
wastewater was toxic to 25% of invertebrates in whole
effluent toxicity tests.

To my knowledge, there has been absolutely no review of
these issues by either the Governor?s office or MDEQ
as to the Great Lakes basin withdrawal policy or
consequences to local water well consumers in the
Ithaca area.   Anyone reading this may correct me
if I?m wrong.

This is an example of the kind of problem that MDEQ
allowed to happen with excessive groundwater
pumping in the Milan area for local mining and from
irrigation in the thumb.....no consideration being given
to local property owners, protection of wetlands and
well operations near the site of this ?giant sucking
sound? [as Ross Perot might say] from ethanol plant
water mining operations.

This is all to benefit corn farming with higher corn prices
which is hardly a green industry.   Corn farming is
one of the most polluting enterprises we have in Michigan
and is responsible for massive soil/sedimentation losses
and widespread river turbidity pollution.....another
problem which MDEQ water pollution planners take
a blind eye to with failure to list extensive polluted
watercourses for turbidity on the Clean Water Act
303d list of impaired watercourse....another MDEQ
nod to big agriculture.


Greenhouse Gas Emissions from Liberty Renewable Fuels

Jennifer Granholm doesn?t hold a candle to Arnold
Schwarzenegger or some of the Northeastern US states 
when it comes to moving on state consideration of the
consequences of greenhouse gas emissions.   Looks like
Jennifer would just as much leave the greenhouse gas/
global warming issue to George Bush to ?handle.?

All carbon dioxide emissions are to be minimized with
approaches to global warming control.  Just because the
carbon dioxide comes from a renewable source doesn?t
mean that such emissions are good or otherwise not harmful.  

The carbon dioxide discharged by ethanol plants is
not chemically or physically distinguishable from
carbon dioxide emitted by coal fired electric power plants.

The Liberty Renewable Fuels facility at Ithaca will be
a prodigious discharger of greenhouse gases from
both fermentation process and from combustion of natural gas.

Based on experience at another plant, Liberty Renewable
Fuels can be expected to discharge about 98,000 lbs/hr of
carbon dioxide from the fermentation process.  

Liberty Renewable Fuels will compete with your home
heating needs as a very large natural gas consumer with
natural gas combustion at about 424 million BTU /hr heat
input, or about 424,000 standard cubic feet per hour (or
4240 CCF per hour).  If a garden variety small homeowner
might use about 800 CCF per year, Liberty Renewable
Fuels will use about the amount of natural gas that
over 46,000 such homes will use per year.

At a plant capacity factor of 95%, Liberty Renewable
Fuels will generate about 408,000 tons/year of carbon
dioxide from fermentation and about 211,000 ton/year
of carbon dioxide from natural gas combustion.....all
for a total of about 619,000 tons of carbon dioxide
as a greenhouse gas emission per year.   That is about
10 lbs of carbon dioxide for each gallon of ethanol produced.

These totals do not include any methane or ethane
(greenhouse gases) discharged by the plants which can
be expected from fermentation operations.   In addition,
this total does not include the carbon dioxide that will be
emitted when the ethanol produced at the plant is burned.

Liberty Renewable Fuels will discharge these
greenhouse gases uncontrolled with no effort at carbon
dioxide sequestration.


Traditional Pollutants

Liberty Renewable Fuels is being permitted under the
Clean Air Act as a minor air pollution source.   All of
the common pollutants are just under the 100 tons per
year major source threshold as depicted by the Applicant.  
The hazardous air pollutants from the plant are just under
the HAP major source thresholds.

All of these issues are under review, but the ethanol production
industry has a history of underestimating their emissions.  
It is not unlikely that this will be repeated at this facility,
given its large size.  Most other ethanol plants now are
being permitted at 100-110 million gallons per year of
ethanol.   Liberty Renewable Fuels is proposing a production
level of 121 million gallons per year of denatured ethanol,
as well as a site grain dryer. 

Whether the minor air pollution source claim can be
sustained awaits further review and examination.

More on this plant with further postings.....

==========================================
Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

657 Spartan Ave,  East Lansing, MI  48823 
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
==========================================