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By Wilma Subra Subra Company P.O. Box 9813 New Iberia, LA 70562 subracom@aol

Environmental and Human Health Impacts of Methanol Plants Northwest Innovation Works Proposed Methanol Plants. By Wilma Subra Subra Company P.O. Box 9813 New Iberia, LA 70562 subracom@aol.com. Northwest Innovation Works Methanol Plants.

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By Wilma Subra Subra Company P.O. Box 9813 New Iberia, LA 70562 subracom@aol

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  1. Environmental and Human Health Impacts of Methanol Plants Northwest Innovation Works Proposed Methanol Plants By Wilma Subra Subra Company P.O. Box 9813 New Iberia, LA 70562 subracom@aol.com

  2. Northwest Innovation Works Methanol Plants • Northwest Innovation Works is associated with Chinese Academy of Science Holding Co., Ltd. Which is part of the Chinese government that develops and takes new technologies to market. • Northwest Innovation Works is proposing to construct three methanol plants and export facilities. The plants are designed to convert natural gas to methanol. • Port of Tacoma, tide flats, Washington • Port of Kalama, Washington • Port of St. Helens (Port of Westward – Near Clatskanie), Oregon

  3. Northwest Innovation Works Methanol Plants • The three Northwest Innovation Works proposed methanol plants in Washington and Oregon are scheduled to produce approximately 14.4 million metric tons of methanol on an annual basis. • This will be more than twice the 6.5 million metric tons produced on an annual basis by the current seven operating United States methanol facilities. • The Port of Tacoma Northwest Innovation Works methanol facility will be the largest of the three methanol facilities being proposed by Northwest Innovation Works. The Port of Tacoma proposed methanol production, 7.3 million metric tons per year, will be equal to the production of both of the other two proposed facilities combined and greater than the current methanol production by the seven operating U. S. methanol facilities.

  4. Tacoma Methanol Plant – Blair Waterway at Port of Tacoma • Site of former Kaiser Aluminum Smelter • 30 year lease with the Port of Tacoma for 90/125 acre site – May 2014 • $3.4 billion natural gas to methanol plant being proposed • 4 methanol production lines, each 5,000 metric tons per day • Total 20,000 metric tons per day of methanol production • 1,000 construction jobs • 260 full time managers and workers when in operation • Nearby facilities – Schnitzer Steel, Targa Sound Terminal, Port of Tacoma breakbulk and containerized cargo facilities, and within the blast zone of LNG plant. • 2015 – 2018 permitting process • 2018 planned to begin construction • 2020 planned to begin operations • Scoping process for Environmental Impact Statement ends March 4, 2016

  5. Port of St. Helens, Port of Westward near Clatskanie, Lower Colombia River, Oregon • $1.6/$1.8 billion natural gas to methanol plant being proposed • 240 full time jobs during operations • Permitting process to begin 2016 • Nearby facilities two natural gas power generating stations, and ethanol and oil exporting facility

  6. Port of Kalama Methanol Plant – Lower Colombia River, Washington • 30 year lease with Port of Kalama signed April 2014 • $1.6/ $1.8 billion natural gas to methanol plant being proposed • 240 full time jobs during operations • 2018 planned to begin operations • Nearby facilities include manufacturing plants and industrial gas facilities • Scoping of Environmental Impact Statement occurred in 2014 • Draft Environmental Impact Statement due March 2016

  7. Three Phase Process of Methanol Production • Synthesis gas production (syngas) from natural gas • Synthesis of crude methanol • Methanol distillation Synthesis Gas Production • Desulfurization –remove sulfur with zinc oxide and produce zinc sulfide • Pre-reforming of natural gas • Steam methane reformer (SMR), reforms methane into a raw syngas stream • Raw syngas mixed with pre-reformed natural gas stream • Secondary reforming process where oxygen is introduced as reforming agent

  8. Methanol Synthesis • Syngas routed to the methanol synthesis two step process • Twin water cooled reactor, highly reactive catalyst to partially convert syngas to methanol • Partially converted process gas stream is routed to the gas cooled methanol reactor with catalyst bed • Raw methanol produced Raw Methanol Distillation • Impurities separated into overhead vapor stream • Two methanol columns in series further distill the methanol • Produce grade methanol

  9. Focus on Northwest Innovation Works Tacoma Methanol Plant The Tacoma methanol facility will generate methanol feedstock for the manufacture of olefins in China. The olefins will be used to manufacture plastics in China. The Tacoma Methanol plant will consist of: • Four methanol production lines (5,000 metric tons per day per line) • Administrative and lab building • Air separation units • Storage tanks • Fire suppression facilities • Wastewater treatment facility • Water treatment facility • Cooling towers • Flare system • Emergency generators • Associated ship docking facility connected via pipeline • Fifteen additional acres will be required for storage tanks • 4 to 7 ships per month to be loaded with methanol and shipped to China

  10. Tacoma’s Attraction for Methanol Plant • Skilled work force experienced in construction and operating industrial facilities • Area resources – natural gas, water, clean energy • Existing infrastructure and property zoned for heavy industries

  11. Methanol Plant Required Water Usage • Water usage identified as a concern • Initial water usage 10,000 gallons per minute (14.4 million gallons/day) • Revised water usage 7,200 gallons per minute (10.4 million gallons/ day) • 3.7 million gallons per year • 28% reduction based on maximizing treatment and reuse waste water by the methanol plant • 90% of water use for cooling • 80% of cooling water released into the air as vapors

  12. Tacoma Public Utilities • Tacoma Public Utilities (TPU) has stated its utility has ample water to meet the needs of industrial customers including NWIW without affecting residential water use. • Northwest Innovation Works is considering working with the City of Tacoma to investigate the feasibility of using city waste water for facility needs.

  13. Methanol Plant Waste Water • Waste Water Identified as an issue • The Tacoma methanol plant will generate 1.44 million gallons of waste water per day. The waste water will be treated onsite and then discharged to the City of Tacoma waste water treatment works. The waste water will have to meet pretreatment standards before being discharged into the City waste water treatment works. • The temperature and quality of the waste water effluent is of concern due to the potential impacts on aquatic and terrestrial organisms associated with the receiving water bodies. • Storm water will be discharged into the storm water system or the existing Port of Tacoma outfall.

  14. Areas of Concern Associated with the Tacoma Methanol Plant • Increased air pollution burden on ambient air quality as a result of emissions of large quantities of toxic pollutants and associated human health impacts • Release of large quantities of green house gases • Sea Level Rise associated with the increase in emissions of green house gases • Odors and associated health impacts as a result of the Tacoma Methanol Plant operational activities, accidental releases and upset conditions, spills and leaks, and odorize natural gas releases • Increase in noise, dust, air emissions and traffic during construction activities, plant operations and ship loading • Potential for extensive negative environmental impacts • Negative impacts on residential property and commercial businesses in proximity to the Tacoma Methanol Plant • Negative impacts on individuals living and working in the vulnerable zones associated with the release of toxic chemicals and explosions

  15. New Pipeline Lateral Required to Delivery Natural Gas to the Tacoma Methanol Plant A new 10 mile pipeline lateral will be needed to transport out of state produced natural gas to the Tacoma Methanol Plant from the regional pipeline. The odorized natural gas pipeline will go through unincorporated Pierce County, the Puyallup Tribe Indian Reservation, and the cities of Summer, Puyallup ,Fife and Tacoma.

  16. Tacoma Methanol Plant Permits Required • Department of Ecology Water Quality Certification • U. S. Army Corps of Engineers’ Section 10 and 404 permits • City of Tacoma Shoreline Substantial Development Permit • Construction Storm Water Permit • Permit to construct lateral pipeline • Puget Sound Clean Air Agency Construction Air Contaminant Permit • Part 70 (Title V) and PSD Air Emission Permits

  17. Environmental Impact Statement • The City of Tacoma is the lead agency for development of the Environmental Impact Statement (EIS) under the State Environmental Policy Act (SEPA). • The EIS will be used by federal, state and local agencies to evaluate and make decisions on all necessary permits. • The scope of work for the EIS will be based on public out reach and public hearings. • The EIS will document probable adverse environmental impacts from construction and operation of the project. It will determine if the impacts are significant. It will discuss alternative and mitigation measures that may be proposed to avoid or minimize adverse impacts.

  18. Environmental Impact Statement • The EIS will use a tiered analysis approach. Impacts most directly caused by the project will receive the most detailed analysis such as impacts at the site and its immediate environs. Those impacts outside the region will be acknowledged but not receive the same level of scrutiny. Examples of those areas outside the region that will be acknowledged but not receive the same level of scrutiny will be natural gas drilling, fracturing, production and transportation, shipping methanol to China, and olefin production from methanol in China. • The scoping process for the EIS for the Tacoma Methanol Plant began December 15, 2015 and will extend until March 4, 2016.

  19. Yuhuang Chemical, Inc. YCI Methanol Plant – China Company Methanol from Natural Gas • St. James, St. James Parish, Louisiana • Permitted May 2015 • 1,300 acre site purchased in August 2015 • Broke ground on September 8, 2015 • 1.7 million metric tons of methanol per year • Next to Plains all American Pipeline Terminal • 350 to 400 direct jobs

  20. Yuhuang Chemical, Inc. YCI Methanol Plant – China Company • Attractions for site – deepwater channel for ship access on the Mississippi River, cheap shale natural gas available • Plant to ship manufactured Methanol to China • $1.85 billion dollar construction cost, $9.5 million incentive package from the state of Louisiana and work force training • Operations scheduled for 2018 • Same process as 3 Northwest Innovation Works facilities

  21. Air Emissions Permitted to be Released by YCI Methanol Plant • Minor source of criteria pollutants • Major source of federally regulated Hazardous Air Pollutants (HAPs) • Major source of Toxic Air Pollutants (TAPs) • These chemicals are known or suspected cancer causing agents or cause serious health effects • The toxic chemicals to be released in the largest quantities are: • Benzene • Naphthalene • Formaldehyde • Toluene • Methanol • Methanol is a Hazardous Air Pollutant

  22. Green House Gases • Because the facility will be a minor source of criteria pollutants, emissions of greenhouse gases (carbon dioxide equivalents CO2e) need not be quantified or addressed by the permit.

  23. Permit Conditions for the YCI Methanol Plant Air Emissions • PM10 59.37 tons per year • PM2.5 57.92 tons per year • SO2 4.79 tons per year • NOX 85.45 tons per year • CO 88.30 tons per year • Ammonia 31.72 tons per year • VOC 80.49 tons per year

  24. VOCs Air Emissions • Benzene 0.03 tons per year • Formaldehyde 0.56 tons per year • Methanol 43.80 tons per year • n-Hexane 13.35 tons per year • Naphthalene 0.02 tons per year • Toluene 0.03 tons per year

  25. YCI Methanol Facility Units • Steam Methane Reformer • Auxiliary Boiler • Flare • Emergency Generator • Cooling water tower • Crude methanol tank • 5 Methanol production tanks • Ammonia tank • Truck/Rail Car/Loading operations • Marine loading operations • Fugitive emissions • Waste water treatment unit • Administrative Building • Power generating facility

  26. YCI Methane Facility Units Releasing Highest Quantity of Air Emissions PM10 and PM2.5 117.29 tons per year • Steam Methane Reformer 78.32 tons per year • Auxiliary Boiler 34.6 tons per year • Cooling Water Tower 4.09 tons per year SO2 4.79 tons per year • Steam Methane Reformer 3.15 tons per year • Auxiliary Boiler 1.40 tons per year • Flare 0.21 tons per year NOX 85.45 tons per year • Steam Methane Reformer 52.56 tons per year • Auxiliary Boiler 23.08 tons per year • Flare 7.25 tons per year • Emergency Generator 2.16 tons per year

  27. YCI Methane Facility Units Releasing Highest Quantity of Air Emissions CO 88.30 tons per year • Auxiliary Boiler 49.67 tons per year • Steam Methane Reformer 34.78 tons per year • Flare 1.98 tons per year VOC 80.49 tons per year • Steam Methane Reformer 28.34 tons per year • Power Facility 19.80 tons per year • Auxiliary Boiler 12.48 tons per year • Cooling Water Tower 8.65 tons per year

  28. YCI Methane Facility Units Releasing Highest Quantity of Volatile Organic Compounds as Air Emissions Benzene 0.03 tons per year • Steam Methane Reformer 0.01 tons per year Formaldehyde 0.56 tons per year • Steam Methane Reformer 0.39 tons per year • Auxiliary Boiler 0.17 tons per year Methanol 43.80 tons per year • Steam Methane Reformer 4.61 tons per year • Cooling Water Tower 8.65 tons per year • Fugitive emissions 4.31 tons per year • Waste water treatment fugitives 3.00 tons per year • Flare 0.15 tons per year • Tanks 19.8 tons per year

  29. Purpose of Flare • The flare is to control emissions from distillation operations and/or reactor process during periods of start up, shut down, and malfunctions • During normal operations the flare will not be used to control emissions from distillation operations • Flare is not used as a control device • Flare releases methanol

  30. South Louisiana Methanol, LP Methanol from Natural Gas • St. James, St. James Parish, Louisiana • Permit application July 11, 2013 • Permitted December 23, 2013 • Construction has not begun • 1.9 million metric tons of methanol per year • Next to Plains all American Pipeline Terminal • 63 direct jobs • 374 indirect jobs

  31. South Louisiana Methanol, LP • $1.3 billion dollar investment • Attractions for site • deepwater channel for ship access on the Mississippi River • access to natural gas and carbon dioxide pipelines • Plans to ship manufactured Methanol to Asia, Europe and North America. • Same process as 3 Northwest Innovation Works facilities

  32. Permit Conditions for the South Louisiana Methanol Plant Air Emissions • PM10 86.35 tons per year • PM2.5 82.89 tons per year • SO2 6.63 tons per year • NOX 138.63 tons per year • CO 98.92 tons per year • VOC 70.32 tons per year • CO2e 1,303,228 tons per year

  33. Prevention of Significant Deterioration - Significant Levels

  34. Determining Best Available Control Technology • PSD regulations require a top down Best Available Control Technology analysis for each pollutant emitted in excess of the significant PSD Threshold level. • Determine the most stringent control technique available for a similar or identical source. • If it can be shown that this level of control is infeasible based on technical, environmental, energy and/or cost considerations, then it is rejected and the next most stringent level of control is determined and similarly evaluated. • This process was conducted for emissions of PM10, PM2.5, NOx, VOC and green house gases.

  35. Identified Best Available Control Technologies PM10 and PM2.5 • Reformer Good Combustion Practices • Boilers Good Combustion Practices • Cooling Tower High Efficiency Drift Eliminator • Process Flare/Tank Flare Correct Flare Design and Proper Combustion NOx • Reformer Selective Catalytic Reduction • Boilers Low NOX Burners • Process Flare &Tank Flare Correct Flare Design and Proper Combustion

  36. Identified Best Available Control Technologies VOC • Reformer Good Combustion Practices • Boilers Good Combustion Practices • Process Flare/Tank Flare Correct Flare Design and Proper Combustion • Fugitives LDAR Monitoring • Methane Tanks Internal Floating Roof Tank with Inert Gas Blanket • Crude- Off-Spec Tank Fixed Roof Tank with Thermal Oxidizer Greenhouse Gases • Reformer Energy Efficiency Measures (heat recovery) • Boilers Energy Efficiency Measures • Process Flare/Tank Flare Correct Flare Design and Proper Combustion

  37. South Louisiana Methanol Units Releasing Highest Quantity of Air Emissions PM10 86.35 tons per year • Reformer Vent 79.43 tons per year PM2.5 82.90 tons per year • Reformer Vent 79.43 tons per year NOX 138.63 tons per year • Reformer Vent 113.88 tons per year

  38. South Louisiana Methanol Units Releasing Highest Quantity of Air Emissions VOCs 70.32 tons per year • Reformer Vent 57.49 tons per year • Methanol Tanks 5.36 tons per year • Waste Water Fugitives 1.24 tons per year • Process Fugitives 1.18 tons per year Green House Gases 1,303,228 tons per year • Reformer Vent 1,247,374 tons per year • Boilers 40,998 tons per year • Flares 10,796 tons per year

  39. Lake Charles Methanol, LLC Petroleum Coke Converted to Methanol, Hydrogen (H2), Byproducts (Sulfuric Acid, Carbon Dioxide, Argon, and Electricity) • Calcasieu Parish, Louisiana • Adjacent to the petroleum coke port facility from which petroleum coke will be received • Permit application June 3, 2015 • Public Hearing December 29, 2015 • 125 new jobs

  40. Permit Conditions for the Lake Charles Methanol plant air emissions • PM10 70.49 tons per year • PM2.5 69.41 tons per year • SO2 137.10 tons per year • NOX 169.21 tons per year • CO 461.87 tons per year • VOC 18.49 tons per year • CO2e 6,015,208 tons per year • H2SO4 45.01tons per year • H2S 0.15 tons per year The facility is a major source of Title V, PSD and TAP. The facility is a minor source of HAPs.

  41. Toxic Air Pollutants to be Released from Lake Charles Methanol • Ammonia (NH3) 38.12 tons/year • Hydrogen Sulfide (H2S) 0.15 tons/year • Methanol 9.65 tons/year • Formaldehyde 0.01 tons/year • Sulfuric Acid 45.01 tons/year • Cumene 0.01 tons/year • Ethyl Benzene 0.01 tons/year • n-Hexane 0.01 tons/year • Toluene 0.01 tons/year • Xylene (mixed isomers) 0.01 tons/year • Carbonyl Sulfide 0.59 tons/year • Benzene 0.01 tons/year

  42. Prevention of Significant Deterioration - Significant Levels

  43. Identified Best Available Control Technologies PM10 and PM2.5 • Auxiliary Boilers/Steam Superheaters - Good engineering design and proper operations • Wet Sulfuric Acid Plant – Sulfuric Acid condenser and hydrogen peroxide scrubber • Flares – Good flare design • Cooling Tower - Drift Eliminator • Coke Handling – Bag houses • Rod Mill Vents – Good equipment design and proper operation • Gasifier Start-up Preheat Burners - Good engineering practices, good combustion tech. and use of clean fuels SO2 • Auxiliary Boilers, Steam heaters – Fuel gases and/or pipeline quality natural gas • Wet Sulfuric Acid Plants – Hydrogen peroxide scrubber

  44. Identified Best Available Control Technologies CO • Auxiliary Boilers, Steam heaters - Good combustion practice and good engineering design • Wet Sulfuric Acid Plants - Good combustion practice and good engineering design • Flares – Good flare design • Acid Gas Removal Unit, CO2 Vent – Route to RTO for control • Regenerative Thermal Oxidizer - Good combustion practices and good engineering design Greenhouse Gases • Auxiliary Boilers, Steam heaters - Good combustion practice and good engineering design • Wet Sulfuric Acid Plants - Good equipment design and good combustion practices • Flares – Good equipment design and good combustion practices • Acid Gas Removal Unit, CO2 Vent – Route to RTO for control • Regenerative Thermal Oxidizer - Good equipment design and good combustion practices • Gasifier Start-up, Preheat burners – Good equipment design and good combustion practices

  45. Lake Charles Methanol Units Releasing Highest Quantity of Air Emissions PM10 70.49 tons per year • Wet Sulfuric Acid Unit Cap 45.02 tons per year • Cooling Water Towers 14.13 tons per year PM2.5 69.41 tons per year • Wet Sulfuric Acid Unit Cap 45.02 tons per year • Cooling Water Towers 13.45 tons per year SO2 137.10 tons per year • Wet Sulfuric Acid Unit Cap 97.99 tons per year • Thermal Oxidizer 38.04 tons per year

  46. Lake Charles Methanol Units Releasing Highest Quantity of Air Emissions NOX 169.21 tons per year • Wet Sulfuric Acid Unit Cap 119.88 tons per year • Steam Superheater Group 17.73 tons per year • CO 461.87 tons per year • Thermal Oxidizer 168.08 tons per year • Wet Sulfuric Acid Unit Cap 161.65 tons per year • H2SO4 45.01 tons per year • Wet Sulfuric Acid Unit Cap 45.00 tons per year • Green House Gases 6,015,208 tons per year • Thermal Oxidizer 5,232,602 tons per year

  47. Summary of Emissions from Three Methanol Plants in Louisiana (tons per year) to get a Perspective on the Potential Emissions from the Tacoma Methanol Plant (7.3 million metric tons of Methanol per year)

  48. Routes of Human Exposure to Chemicals Associated with Methanol Plants • Inhalation • Ingestion • Dermal contact

  49. Health Impacts of Chemicals Released by Methanol Plants Benzene • Known human carcinogen – leukemia • Teratogen in animals • Irritates skin, eyes, nose, throat • Causes coughing, wheezing, dizziness, headaches, lightheadedness Formaldehyde • Known human carcinogen – nasopharynx and leukemia • May damage developing fetus • Affects female fertility • Irritates lungs, skin, eyes, nose, throat Naphthalene • Probable carcinogen in humans – larynx and intestines • Irritates skin, eyes, nose, throat • Causes headaches, fatigue, nausea and vomiting

  50. Health Impacts of Chemicals Released by Methanol Plants Toluene • May be teratogen • May damage developing fetus • Irritates skin, eyes, nose, throat • Affects nervous system Xylene • Damages liver and kidneys • Damages developing fetus • Irritates skin, eyes, nose, throat • Causes headaches, nausea, vomiting, wheezing, dizziness, lightheadedness n-Hexane • Damages testes • Irritates and burns skin and eyes • Irritates nose, throat, lungs • Causes headaches, nausea. vomiting, coughing, wheezing, shortness of breathe, dizziness, lightheadedness

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