Meanwhile, the company, which operates similar facilities across the Southeast, faces financial challenges that sent its stock price plunging from a high of more than $82 in April 2022 to less than $1 in November, and triggered a class-action lawsuit by disgruntled shareholders.
That freefall has fueled fears by critics of the pellet industry who worry that cost-cutting efforts by Enviva will lead to more pollution.
The federal Clean Air Act sets thresholds for 188 types of toxic emissions considered particularly dangerous for people and the environment. Limits for facilities in the Waycross plant's classification are capped at 10 tons per year for individual hazardous pollutants and a combined 25 tons per year for all highly unhealthy emissions.
In a filing with the Georgia Environmental Protection Division’s Air Protection Branch, Enviva estimates that when running at capacity, the Waycross plant could release a maximum of nearly 45 tons per year of methanol, which is one of the regulated toxins, and total hazardous pollutants at a rate of 79 tons annually.
Methanol, also known as wood alcohol, is a poisonous substance that can be absorbed through the eyes, skin, lungs and digestive system, and overexposure can lead to death, according to the Centers for Disease Control and Prevention.
The document also notes that Enviva expects annual pellet production to exceed 920,000 tons, the total on which those "potential-to-emit estimations” are based.
"So if they've exceeded 920,000 tons, they're probably emitting even more than 79 tons per year (of hazardous air pollutants) for the given time period," said another SELC attorney, Patrick Anderson.
That would be three times the allowable total.
In a response to the Savannah Morning News, Enviva disputed that conclusion.
"Stating that our Waycross facility has been emitting three times the legal limit for hazardous air pollution is an inaccurate statement that does not capture the permitting steps, investments in emissions control technology, and conservative approach taken by Enviva," the company said in an email. "The modelling effort that Enviva conducted with the Georgia Environmental Protection Division was in accordance with the Agency’s guidance and demonstrated a high margin of compliance against the state’s standards which are established to ensure human health is not adversely affected."
That "modelling effort," the company explained, involved 15 toxic air pollutants, as defined by Georgia EPD, and found that the Waycross facility "does not pose a risk to human health."
But the SELC's Hillaker countered that Enviva is "cherry-picking different standards," including for acrolein, a particularly harmful pollutant.
Furthermore, estimates related to a handful of pollutants don't change the company's projections for overall hazardous emissions, she added.
"Enviva’s calculations are based on how the facility is intended to be operated and Enviva has provided no information/documentation/evidence that they have adjusted their operations in a way that would reduce the facility’s actual emissions below what was estimated," Hillaker said. "If Enviva has production records or (smoke) stack tests demonstrating that they have not exceeded their (hazardous air pollution) emission limits, they can provide it. Until then, the only evidence to go on is their own emission calculations and EPD’s statements."
And the Environmental Protection Division, in its own 31-page written review of Enviva's application for a revised air-quality permit, notes that the Waycross facility "is technically out of compliance with the major source HAP avoidance limits."
‘It’s quite ridiculous, absurd’
In that request, Enviva details plans to boost production at the Waycross facility from the currently allowed 920,000 tons of pellets annually to 970,000 tons.
"It's not just that they're seeking the production increase," Hillaker said. "They've told the Georgia Environmental Protection Division that they will be exceeding that limit and are actually asking for the permit to validate what they plan on doing anyway."
Enviva’s current state air quality permit, issued in 2019, designates the Waycross plant as a minor source of hazardous pollution. The classification includes the annual emissions limits that are being exceeded by the facility.
“They’ve really been operating as a major source (producer) without a major source permit,” Hillaker explained. “It’s quite ridiculous, absurd that they are now asking to increase their production limits while they’re still actively violating the emissions limits.”
The company now is requesting a “significant permit modification” that would allow for three times more hazardous air pollution annually and reviews of individual pollutants on a case-by-case basis.
"Consistent with the environmental permit requirements, the Waycross facility applied to modify the air permit after the 2021 source testing to reclassify the site as a major source of hazardous air pollutants," Enviva said in its email to the Journal.
Critics agree with that description, but differ in their perspective.
“They’re doubling down (by) telling the (Environmental Protection Division) they’re going to violate their production limits and then asking EPD to essentially permit that by expanding their production amount,” Hillaker said, referring to Enviva.
In its written comments to the EDP in response to Enviva's requested permit changes, Hillaker's organization notes that the Clean Air Act requires a facility to employ "maximum achievable (pollution) control technology" to qualify for case-by-case review as a major source of hazardous air pollutants.
In its comments to the Morning News, the company said a review of the Waycross facility determined it "already had the required environmental pollution control equipment in operation, and therefore, no additional emission controls or modifications to the site were needed to comply as a major source of HAPs."
However, the SELC argues that the company’s application describes processes that fall well short of what’s being done at other comparable operations.
Is the wood pellet industry climate friendly?
Enviva positions itself as a frontline contributor in the fight against climate change.
“Wood-based bioenergy is part of an all-in renewables strategy to reduce carbon emissions and limit dependence on fossil fuels,” the company claims in its promotional material.
Advocates for the pellet industry point to research concluding that the production process is “carbon-neutral” because, with effective reforesting, there is no net loss in carbon-absorbing tree cover.
“These studies build on the scientific literature that consistently shows existing regulations are working as intended to ensure biomass is responsibly sourced in the U.S. Southeast to provide a positive impact on the climate and the environment,” Amandine Muskus, executive director at the U.S. Industrial Pellet Association, said earlier this year in response to a study published in the journal Nature.
However, critics counter that those assessments don’t consider the full "value chain" of the pellets – a process that determines the true climate impact across the entire lifecycle of a product.
In the preproduction stage for pellets, trees are cut using machinery then trucked to a facility.
At the plant, the wood is reduced to sawdust – typically by machinery powered at least in part by fossil fuels – then formed into into pellets.
In the case of the Waycross plant, nearly 1 million tons of the pellets produced annually then are carried by trucks to the Port of Savannah, loaded on ships and transported to Europe, where they are burned as an alternative to coal.
Heat-trapping pollution that contributes to climate change is produced at each stage.
“It takes a very long time before you can sequester the amount of carbon that was emitted at the time of the (tree) harvest and the (related) combustion,” Hillaker explained. “So, if you look at this in a 150-year timeframe, maybe you'll get to some point of ‘carbon neutrality’ or ‘carbon parity.’ But we don't have 150 years.”
Over the past decade, wood pellet facilities in the Southeast have been hit with nearly 60 environmental or occupational citations and nearly $7 million in related fines, according to the SELC. Nearly two-dozen of those actions involved Enviva plants.
There have been no reported violations in Waycross since the company bought the facility for $175 million in 2020, although the previous owners were fined $100,000 for infractions a decade ago.
John Deem covers climate change and the environment in coastal Georgia. He can be reached at firstname.lastname@example.org.
This article originally appeared on Savannah Morning News: Georgia has world’s largest wood pellet factory, and state says its exceeding pollution limits
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