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Yes, attached is a link to the public meeting. Everyone had access to sign up for questions and DEQ did their best to answer with factual information. Much of their research was mentioned in this meeting. Click the link below to access:
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International Tie Disposal LLC (henceforth ITD) is intending to build a recycling operation to transform wood products (especially legacy & junk railroad ties) into an environmentally friendly material called biochar. This is accomplished through use of vacuum sealed kilns exposed to extreme heat. Legacy & junk railroad ties are deteriorated railroad ties ages approximately 15-30 years old and are no longer suitable for secondary markets. Much of the creosote has leached from the tie. At this facility the ties will be shredded and put in the kilns. ITD is owned by Polivka out of Weddington, NC. Polivka is a 3rd generation family business which specializes in paving & design build rail for all Class 1 railroads.
No. The Richmond Board of Commissioners did not recruit nor rezone on behalf of International Tie Disposal.
The Richmond County Commissioners voted to re-zone property along the CSX Hamlet rail yard to Heavy Industrial upon the unanimous approval and recommendation of the planning and zoning board. CSX submitted a request that all CSX owned property in Richmond County be rezoned to heavy industrial. The property was found to be consistent with the land use plan of Richmond County & is adjacent to a heavily used rail yard & within an industrialized area.
ITD will generate $2.5M in gross salary to Richmond County employees (making on average of $22 per hour; $18, starting; $25, upper), and will invest up to $12 million dollars in infrastructure at its proposed facility. Maintenance and other services will be required of local contractors.
The Richmond Community College will provide key talent and training to its workforce of 55 employees, with higher than average salary for the region.
Lastly, ITD will be a valuable, contributing member of the local community, as it has at its corporate office in the town of Weddington, North Carolina.
ITD is not burning railroad ties. There is no combustion in the process. The process of pyrolysis will heat the wood in an air starved kiln to a degree that the chemicals will turn into gas. This process takes place in a vacuum sealed kiln with no visible emissions.
Pyrolysis, the chemical decomposition of organic (carbon-based) materials through the application of heat. Pyrolysis, which is also the first step in gasification and combustion, occurs in the absence or near absence of oxygen and it is thus distinct from burning, which can take place only if sufficient oxygen is present. Hence why the air sealed kilns are being used by ITD. The rate of pyrolysis increases with temperature. In industrial applications the temperatures used are often 430 °C (about 800 °F) or higher, whereas in smaller-scale operations the temperature may be much lower. Two well-known products created by pyrolysis are a form of charcoal called biochar and coke (which is used as an industrial fuel and a heat shield)
DEQ is the regulatory agency regarding the Air Quality Permit. To date, ITD has received their ’draft permit’ from DEQ, however DEQ is still holding a public hearing on this project. DEQ is a state regulatory agency appointed by Governor Roy Cooper and has been lead by Michael Regan, who has since moved on as an Environmental Director under the Biden Administration. DEQ has given a platform to environmental justice & environmental groups to ensure North Carolina is being a good steward of the environment. ITD will undergo very strict regulations in order to receive their permit. ITD has filed for a Synthetic Minor permit. Synethic Permits are considered minor sources of pollutants as compared to large sources such as Title V permitted facilities.
The North Carolina Department of Environmental Quality, Air Quality, otherwise The North Carolina Department of Air Quality (henceforth, DEQ) “enforces state and federal air pollution regulations. In North Carolina, the General Assembly enacts state air pollution laws, and the Environmental Management Commission (EMC) adopts most rules dealing with air quality. In addition, the U.S. Environmental Protection Agency (EPA) has designated the DAQ as the lead agency for enforcing federal laws and regulations dealing with air pollution in North Carolina.” (NC DEQ: “About Air Quality” https://deq.nc.gov/about/divisions/air-quality/about-air-quality)
In the course of acquiring an air quality permit, the DEQ requires facilities seeking a permit to submit data that follows the testing parameters established by the EPA. This is then used, usually with safety factors, to establish a conservative estimate of the facility’s permit type, whether a Small, Synthetic Minor, or a Title V permit.
The DEQ then works out the particular parameters of the permit with special conditions and other restrictions to ensure the facility meets all applicable ambient air quality standards and requirements.
For ITD’s proposed facility, the DEQ’s draft permit states that the permit would require testing on four (4) kilns within the first 90 days to ensure compliance with the air quality permit’s established limits for a Synthetic Minor Permit.
Additionally, continuous monitoring is specified with data that ITD will need to submit to the DEQ for review. This will also ensure compliance with all applicable law, and the proposed permit limitations.
If you are interested in participating in the public hearing, below is the relevant information & links:
Questions will be answered at the public meeting, while comments will only be received at the public hearing. Comments will be accepted until 5 p.m. March 3, 2021.
The online public meeting will be held at 6 p.m. on Feb. 22, 2021. It can be accessed toll-free by calling +1 (415) 655-0003 and using the access code “178 013 3745.” The WebEx link is https://bit.ly/3cbemdt, and the event password is “NCDAQ.”
Those who wish to speak at the public meeting must register by 4 p.m. on Feb. 22. To register, visit https://bit.ly/3ogUGYm or call (919) 618-0968.
The public hearing will be held at 6 p.m. on March 1, 2021, also virtually. It can be accessed toll-free by calling +1 (415) 655-0003 and using the access code “178 470 3734.” The WebEx link is https://bit.ly/39golwj, and the event password is “NCDAQ.”
To speak at the public hearing, you must register by 4 p.m. on March 1. To register, visit https://bit.ly/3iJjiHU or call (919) 618-0968.
A majority of the legacy railroad ties will be transported via rail, so there will be minimal truck traffic
ITD modified its original permit based on residents’ concerns over noise pollution generated from the shredding operation. Instead of a diesel operated shredder, the facility will now utilize an electrically powered “chomper.” Additionally, the “chomper” will be housed in an intermodal container, which will have a sound dampening effect.
ITD’s anticipated sound levels will likely be lower than that generated by daily Amtrak and freight trains at the Hamlet CSX facility. By comparison, a shredder has a decibel scale (henceforth, dBA) of roughly 75, whereas a freight train has a dBA of 80. The horn on a train is roughly 130 dBA.
ITD intends to install tree lines and barriers to ensure the facility has reduced visibility & reduced sound.
ITD will be required to apply for all applicable state permits, including stormwater permitting. Due to the site modifications, this will likely require retention ponds. ITD will rely on the relevant state department that issues the stormwater permit to ensure its compliance with best practices. In order to easeconcerns, ITD intends to use a geo-tech style mat which will retain heavy liquids and chemicals from seeping into the soil As with most industrial sites, this will likely require a retention pond or utilize a nearby retention pond.
The partner’s facility in Colorado does not pyrolyze cross ties, just for the tests, as noted. That said, the air quality reports for both are nearly equivalent - the creosote treated wood has slightly cleaner emissions.
Additionally, the DEQ has air quality tests required within 90 days of construction. This is done to make sure the results match what we have been permitted for. It is important to note that we have a 25% safety factor in our emissions calculations, meaning they are very conservative. The DEQ has the results obviously of both the dead timber and cross ties emission tests. This facility will have a similar appearance to the site in Colorado.
Below is a link to BioChar now: https://www.youtube.com/watch?v=3zVqJ1K6eHM
The Biomass energy facility operated by Dominion Power in Georgia utilized railroad ties as a feedstock. There are concerns by some residents that the complaints of odor and smoke associated with the Biomass energy facility in Georgia will similarly apply to ITD’s facility due to it utilizing the same feedstock, that is, railroad ties.
Although the feedstock is similar (railroad ties), the Biomass energy process and the process utilized by ITD are completely different. Biomass energy actually burns railroad ties to create energy, whereas ITD neither burns, nor creates energy with its feedstock. Biomass power operates very similarly to coal power, with a similar pollution profile. Moreover, Biomass power generally operates under the Title V category permit, which is for facilities with high pollution, unlike ITD’s facility, which would operate under a Synthetic Minor permit.
Additionally, ITD’s kiln exhaust system has no visible emissions.
The complaints of odor apply to most Biomass energy facilities, regardless of feedstock. One study found that 7 out of 9 Biomass energy facilities in Europe received odor complaints. Another study found odor associated with the presence of sugar in hardwoods. Due to the legacy tie feedstock (30 - 40 years old) utilized by ITD, ITD does not anticipate the sugar present in the legacy tie feedstock to be sufficient to generate odors.