Petroleum Coke:What do we really know about

what may become the primary fuel at the

Wolverine Clean Energy Venture?

Presented by: Jim Dulzo, Michigan Land Use Institute

Tom Karas, Michigan Energy Alternatives Project

Obtaining, burning, and disposing of PETROLEUM COKE are all causes for major concern.

We want to look at each of these concerns:

SourcesOn-Site Storage

Burning/Emissions Waste Disposal Issues

Where does this fuel come from?How dirty is it?

Wolverine identifies the controversial BP Whiting Refinery in Indiana as one possible source.

Whiting wants to produce oil from tar sands in Canada, and would then use the refinery waste from that oil to produce petroleum coke. Because tar sands have higher sulfur and toxic heavy metal content than regular crude, the petroleum coke that Wolverine would get from BP would likely have even higher concentrations of those materials than “standard” pet coke.

So, one of the main concerns is the quality of the petroleum coke--how much sulfur and toxic heavy metals it contains. Is Wolverine going to buy the cheapest (dirtiest) or the more expensive (cleaner) pet coke available?

Questions about storing pet coke.

Petroleum Coke is very dusty. So it is important to look closely at how Wolverine plans to protect the community from fugitive dust.

Fugitive dust from piles of uncovered pet coke piles have created problems all over the country.

Here is a photo of a dusty fuel pile from a coal plant in Maryland. Since pet coke is dustier than coal, the picture for Rogers City on a windy day would be even worse.

Dust plume

Photo by Tim Berkoff, Crofton 1st

Dust plumes like the one above are a frequent sight when fuel supply piles are left unprotected.

Port of L.A. Covers Its Petroleum CokeBy Sandra Murillo

LOS ANGELES--After years of public outcry, lawsuits and environmental studies, politicians and officials at the Port of Los Angeles announced Thursday that all petroleum coke piles at the port have been covered.

Petroleum coke, a coal-like byproduct of the oil refining process, is exported to Asia for use as an industrial fuel. If inhaled in sufficient quantities, the material can cause cancer, officials said.

Studies have shown a link between elevated levels of coke dust in the air and the deaths of people with respiratory illness and heart disease. An early study in Long Beach showed that coke dust comprised 12% to 15% of air pollutants.

The L.A. Times news article goes on to quote Port of Los Angeles manager Lowenthal, who says of the petroleum coke that passes through his facility,

“We ship out some of the worst stuff in the world.”

Note the two black domes, built specifically to contain pet coke dust. It took many years of litigation to force the Port Authority to take these protective measures.

DTE Pet CokeVicksburg, MS Facility

1,400 Ton pulverized

petcoke storage silo

Barge unloading to 10,000 ton

covered storage

Here’s another example of covered storage for Pet Coke…

What will Wolverine do to contain fugitive pet coke dust and ash?

Not much, apparently. Wolverine’s DEQ permit application says that the largest fuel pile, almost 500,000 tons--about two-thirds of all on-site fuel--will have NO dust suppression.

What about emissions from burning Pet Coke?

Let’s look at what the federal government said in a 2006 report detailing all of the

electrical generating units in the country.

This report details 4,851 electrical generating plants.

Of those plants, the number that reported using petroleum coke in 2006 as a

primary fuel was..

Two!Lets compare those two petroleum coke plants with two existing Michigan coal plants…

eGRID2006 2004 file plant sequence number

State abbreviation Plant name Plant operator name

Plant primary fuel

Plant primary coal/oil/gas fossil fuel category

1996 LA CII Carbon LLC CII Carbon LLC PC OIL

4255 TX Seadrift Coke LP 76 Seadrift Coke LLC PC OIL

2284 MI Belle River Detroit Edison Co SUB COAL

2363 MI J H Campbell Consumers Energy Co BIT COAL

Notice that the federal government clearly classifies petroleum coke differently than coal.

If the federal government makes that distinction, how can anyone claim that petroleum coke is the same as coal?

eGRID2006 2004 file plant sequence number

State abbreviation Plant name Plant operator name

Plant primary fuel

Plant ozone season

NOx input

emission rate (lb/MMBtu)

Plant

annual SO2

input emission rate (lb/MMBtu)

Plant

annual CO2

input emission rate (lb/MMBtu)

1996 LA CII Carbon LLC CII Carbon LLC PC 0.700 7.252 222.875

4255 TXSeadrift Coke LP 76 Seadrift Coke LLC PC 0.875 8.238 222.864

2284 MI Belle River Detroit Edison Co SUB 0.176 0.606 204.780

2363 MI J H CampbellConsumers Energy Co BIT 0.279 0.736 205.200

Clearly, burning pet coke is dirtier than burning coal. Here, Pet Coke emits at least four times as much NOx and 10 times as much SOx per BTU than coal. That means far more smog, acid rain, and bad health effects, particularly for those with asthma, breathing difficulties, and heart disease. And since burning Pet Coke emits 5 to 8 percent more carbon (CO2), the savings from burning this dirtier, cheaper fuel could be canceled out by the carbon tax the federal government will soon impose on such emissions.

The same spread sheet lists each plant’s pollution emissions:

But won’t the MDEQ make sure that what is coming out of the smokestacks is always as clean as technically possible?

Not necessarily. Seeking “fuel flexibility,” Wolverine has conveniently prepared its DEQ air permit application so that the emissions controls would run at full throttle only under the worst-case fuel scenario. In other words, they won’t have to run pollution equipment at full throttle unless they use the dirtiest fuel. What they haven’t put forth is how low they can get air pollution levels when burning the cleanest fuel and running control equipment at full capacity. But this is what the Clean Air Act requires.

Why doesn’t Wolverine’s Clean Energy Venture want to run pollution equipment at maximum capacity all the time, instead of just when it burns the cheapest, dirtiest fuel?

According to their own application, Wolverine plans to do as little as possible to control both fugitive dust and controlling smokestack emissions.

The planning commission has the power to require Wolverine’s best efforts on this. The company is NOT motivated to make that effort, because it reduces their bottom line.

This commission can decide whether Wolverine operates as cleanly as possible, or as cheaply as possible. Which will it be?

The waste stream from petroleum coke is much larger than from coal because, when burned, pet coke loses only 50% of its volume. In addition, pet coke ash contains far higher levels of toxic heavy metals than coal ash does.

What about the waste stream from Petroleum Coke?

“The biggest drawback with this technology [CFB] is that it produces large amounts of solid waste (almost 1.5 to 2.0 times as much as PPC technology and 30 to 40 times as much as CGCC technology).

The waste stream could be even higher because of the type of boiler Wolverine wants to use--Circulating Fluidized Bed. The World Energy Council, an industry trade organization, explains the problem like this…

The report goes on to say, in reference to petroleum coke, that, given that the plant will inject limestone to capture sulfur emissions….

“With very high sulfur content (7 to 8 percent), the quantity of waste can be as much as 50 percent of the amount of petroleum coke burned. If local ash disposal cannot be accommodated at a reasonable cost, this technology may not be economically feasible. http://217.206.197.194:8190/wec-geis/publications/default/tech_papers/17th_congress/1_2_26.asp#top

So, there are three things making the Wolverine Clean Energy Venture’s solid waste stream worse:

3. It will largely use petroleum coke, which loses only half of its mass when burned.

5. It uses CFB technology, which is known for higher rates of waste production than other kinds of burning technologies.

7.With high sulfur fuels, the use of limestone to control those emissions contributes even more to an already very large waste stream.

“…CFB boiler ash cannot be used as a cement replacement in concrete due to its unacceptably high sulfur content. The

disposal in landfills has been the most common means of

handling ash in circulating fluidized bed boiler power plants. However, for a 300 MW CFB boiler power plant, there will be

600,000 tons of ash discharged per year…”

So, can that huge amount of waste be used somewhere else as an industrial byproduct, and how much will Wolverine’s plant generate?

Source: http://scitation.aip.org/getabs/servlet/GetabsServlet?prog=normal&id=JERTD2000128000004000311000001&idtype=cvips&gifs=yes

If Wolverine’s “Clean Energy Venture” produces waste with significantly elevated toxic heavy metals compared to coal, and it cannot be used as an industrial by-product, where will it go?

Apparently, Wolverine wants to put it in an onsite landfill. But its SUP application said nothing about designing that site to handle pet coke ash, which has significantly more toxic heavy metals than coal ash.

And since the plant, by Wolverine’s own estimate, will produce 910,000 tons of such ash a year, the company will eventually have to truck the waste elsewhere—to the tune of 160 semi loads per day. The county must come to an agreement with Wolverine about paying for the heavy wear and tear on roads, assuring safe transport, and protecting air quality, community peace and quiet, and Presque Isle County’s quality of life from such heavy, dangerous traffic.

These kids go to school near a coal plant in Pennsylvania. Will Rogers City schoolchildren have to protect themselves like this as truckloads of pet coke waste material are transported to disposal every day?

And, given that much larger waste stream, who will pay for the expansion of your local landfill and upgrading it to handle toxic ash?

Many people take the view that the MDEQ is responsible for protecting Rogers City and Presque Isle County from the harmful effects of operating a new fuel-burning power plant…

MDEQ has the responsibility to protect the community’s health. And just as that agency can be more stringent than the federal government, the planning commission can be more stringent than the state. That, in fact, is the whole point of having a local planning commission. State-based analyses often do not pay enough attention to the kind of special, local concerns we are raising in this presentation. But you and your fellow commissioners can. If Wolverine insists on calling this project its Clean Energy Venture, you have the power to make sure they take every step possible to live up to that title.

The Presque Isle County Planning Commission should:

•Make sure all fuels, particularly pet coke, have proper storage and dust controls--from ship, to stockpile, to boiler.

•Require Wolverine Clean Energy Venture to attain maximum cleanliness for each fuel, rather than the minimum that the dirtiest fuel’s rules allow.

•Make sure that onsite waste storage protects the local water table, the ambient air, workers, and the community from highly toxic pet coke ash.

•Make Wolverine responsible for financing the road expansions and repairs that 160 daily round trips by heavy semi trucks require.

•Require Wolverine to protect the community from the health, safety, traffic, noise, and quality of life hazards of heavy trucking of toxic waste.

•Require Wolverine to finance, maintain, and bond for the construction, operation, and eventual closing down of a toxic waste storage site.

Why must you address these legalities and technicalities?

•When you buy a new car or hire someone to perform a service, it is ALWAYS best to get a written guarantee.

•Wolverine’s Special Use Permit is that written guarantee. Currently, the document is so vague that it would be of little use in a court case if there was ever a problem with Wolverine’s Clean Energy Venture.

•Once Wolverine’s SUP allows petroleum coke, the PIPC will be unable to change or improve the operation without costly litigation.

•Requiring these guarantees from Wolverine will NOT slow down the plant, unless the firm wants to fight these common-sense points.

•Requiring these guarantees will protect the community’s health, welfare, and safety far more effectively than the current SUP.

•PIPC is the first and last line of defense for this region’s health, safety, and welfare. If you do not rise to this occasion, who will?

So, those are the special challenges of handling, burning, and disposing of petroleum coke.

Remember…Pet Coke is not coal. And it is dirtier than coal.

But it is cheaper than coal.

Do not let Wolverine’s attempt to boost its bottom line by burning cheap fuel unnecessarily harm the community. Health, safety, and welfare are always more important.

These steps are reasonable, wise, and necessary. So is the call for a public hearing before allowing Wolverine to add petroleum coke to its fuel mix.

Thank you for your time and consideration.