Comment submitted by H. Thorp

April 25, 2006 Attn: Docket ID No. EPA-HQ-OAR-2006-0089 U.S. Environmental Protection Agency EPA West (Air Docket) 1200 Pennsylvania Avenue, Northwest B102, Mail code 6102T Washington, DC 20460 I am writing to strongly oppose the proposed changes to Treatment of Corn Milling Facilities Under Clean Air Act Permitting Programs. I oppose these changes for ethanol manufacturing facilities based on my own experiences. The emissions from these plants are know to make people sick as the USEPA had discovered with the Minnesota 2002 enforcements and the events that have taken place in Lena, Illinois with Adkins Energy, LLC, enforcement. Increasing the levels for PSD from 100 to 250 tpy allows fuel-ethanol producers to emit more conventional pollutants than they are presently allowed under minor status. PSD applies to all pollutants that do not exceed the National Ambient Air Quality Standards (NAAQS) in an area. The NAAQS establish maximum pollution concentration levels to protect public health and welfare from harmful levels of pollutants. Placing a 250 tpy threshold on criteria pollutants emitted by industrial chemical ethanol plants would not allow citizens due process to protest. They will not have any say on a minor source permit with this proposed increased volume of emissions from ethanol manufacturing that will be emitted into their community. Minor source permit applications do not allow citizen envolvement. Their is no requirement for public notice or a comment period on minor source permitting. Any documents submitted by citizens do not become part of the record for a pollution control boards? review and decision on permit applications. I have experienced first hand the effects of polluting emissions from the Adkins Energy, LLC, ethanol plant located 2 miles from my home. I have included photos of this plant in operation. When these photos were taken, the officials of the Adkins Ethanol plant were telling the public that they meet and beat all Federal and State emission standards. Your own environmental scientist Sara Dauk acquired documents in November, 2002, that were to the contrary. Many people were experiencing symptoms of nauseau, vomiting, headaches, asthma attacks, burning eyes & throats, aches in their sides, and the inability to breathe. Precursors to serious health problems. I understand the Adkins plant is another isolated case in the many ethanol cases, but the pollutants remain the same when manufacturing ethanol and what I also know is how these combinations of pollutants can affect a person?s health when they are encountered. Illinois EPA stated in a meeting with a Lena trustee that they DO NOT KNOW what the potential long term health effects can be from breathing the combination of pollutants from a ethanol manufacturing plant. There have been no studies to determine long term effects. Currently the Lena Adkins plant is regulated under a FESOP with emission limits under 100 tpy. I can tell you that there are still people in close proximity that continue to experience some of the before mentioned symptoms with limits under 100 tpy. Increasing the threshold limits would increase the harmful affects inflicted on these people, myself included. My air is not the sewer and dumping site for emissions that can and should be eliminated with the proper controls to protect our health. Raising the threshold would allow these plants to install and run pollution controls at a less stringent level. The air pollutant emissions from ethanol manufacturing begin to occur at the very first process. Grain is delivered to the plant, handled, and milled, tiny particles are released into the air referred to as particulate matter (PM). It is well known that PM is very harmful to human respiratory systems. During fermentation, distillation and drying, volatile organic compounds (VOCs), such as ethanol, and HAPs, such as acetaldehyde, acrolein, formaldehyde, and methanol are released. Many VOCs cause serious harm and even cancer in humans. Carbon monoxide, nitrogen oxides, and sulfur oxides may be generated in one of several combustion operations at an ethanol facility. These oxides can be leathal to humans. VOCs are a group of chemicals that evaporate easily into the air. VOCs react with nitrogen oxides, other contaminants, and sunlight. VOCs are known to directly and indirectly cause health effects in humans. Certain VOCs such as benzene are know carcinogens. VOCs also can react with ozone depleting the protective ozone layer. Reducing VOCs react with carbon monoxide, nitrogen oxides and sunlight to form smog. Smog has damaging effects on plants and causes respiratory problems in humans. The ethanol production process gives off a complex mixture of VOCs, carbon monoxide, nitrogen oxide and sulfur oxide. VOCs come from the Distillers Dried Grain dryer, cooling cyclones, centrifuges, and fermentation and distillation scrubbers, and are emitted into the air to mix with the combustion oxides from an ethanol plant. It was our experience that when you were downwind of the ethanol plant these emissions did not dilute readily in the air. We would experience many symptoms very shortly after exposure. Our only recourse was to remove ourselves from the area. Our homes were volunerable if we had windows open. During high heat seasons a citizens? right to have windows open was eliminated when they were downwind from the plant. Ethanol plants locate themselves in close proximity to residents, schools, and nursing homes. Young children and the elderly are more at risk from harmful effects from the pollutants generated from these plants. I have included pictures showing how close the Adkin?s plant is to the school?s athletic fields and nursing home property. It would be better for the environment if all ethanol plants continued to meet the more stringent criteria, i.e., 100 tons/year. Fuel ethanol is possibly going to continue to be a growing industry with the potential of having a plant as often as every 20 miles in the cornbelt. The 100 tpy thresholds would protect the air humans require to sustain healthy lives. In?the Lena?case, to be considered a FESOP source with 100 tpy threshold, Adkins was required to install a thermal oxidizer, which helped address emissions.?Although, we still experience emissions when we are downwind and still have ill symptoms. On the other matter in the proposal, eliminating fugitive releases from the definition is a concern - all emissions should be counted. Road dust (particulate emissions), leaking pipe valves (VOCs) and the storage of the wet distillers grain are potentially significant sources of fugitive pollutants. Many of the neighbors can tell when there is large quantities of wet distillers grain on hand. Loading and unloading of grain stock also produces large quantities of particulate. I request the fugitive emissions remain counted when determining an ethanol plant?s total emissions for title V, PSD or NSR permitting programs. ? One more problem in Illinois is that?no specific air modeling is required so that emissions at a certain levels are not limited to prevent down-wind issues from occurring. Some states, like Iowa do require certain new sources to perform modeling to minimize these types of issues. I would also like to comment that air modeling should be required of all new ethanol manufacturing construction projects to enable the EPA and state EPAs to accurately assess downwind issues before a permit is issued. ? The criteria pollutants covered by the NAAQS are nitrogen oxides, volatile organic compounds (which are precursors to ground-level ozone), sulfur dioxide, fine particulate, carbon monoxide, and lead (all harmful to humans). Ethanol plants produce large amounts of nitrogen oxides, volatile organic compounds, sulfur dioxide, fine particulate, carbon monoxide and HAPS. All are proven harmful to humans. The role the public is assuming the USEPA is performing, is to make sure their health is protected and is foremost when the decisions are made in permitting. The public?s health will be protected if you do not revise the definition of ?chemical process plants? as it applies to ethanol manufacturing, continue to count fugitive emissions, and do not change the minimum threshold to 250 tpy for the PSD permitting program. We only have one Earth were we can sustain life. Pollutants are harmful. We have technology to eliminate pollutants, that should be the end of the discussions. Sincerely, Heidi Thorp 2273 N. Schlegel Road Lena, Illinois 61048 heidithorp@yahoo.com