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Bio En Questions and Comments from Letters and Comment Sheets
This list of questions provides a summary of questions asked during the public consultation process either in person or on comment sheets. Some comments/questions have been paraphrased, and combined with other similar questions. All comment sheets will be provided to the MOE as part of the consultation report for the permitting of this Facility.
Through review of the questions and comments received, it has been noted that the public has four main concerns regarding the proposed AD facility: odour, trucks, safety and noise. This question and answer (Q and A) summary has been organized to group questions of a similar theme together. A final section is provided to address comments not falling into the four aforementioned categories. A number in parentheses indicates the number of questions/comments posed for each theme as presented in the comment forms received during the public meetings.
Odour (30)
A. The process building will contain an exhaust system that will collect air from the building and will keep the building under a slight negative pressure. This negative pressure will ensure that when the doors are opened, air is sucked from the outdoors instead of being allowed to escape. The air collected from this exhaust system will be treated by a biofilter. Please refer to www.biorem.biz for more information on biofilters and how they have been successfully implemented in Ontario
Q.2 What are the fugitive emissions from the biofilter?
A. All fugitive emissions from the processing building will be vented through the biofilter for treatment. A typical biofilter has a removal efficiency of approximately 90 percent and a stack to increase dispersion. Therefore, there are no fugitive emissions expected from the biofilter.
Q.3 Does the size of the facility in tonnage mean that more odours will be generated?
A. Emission estimates including odour, have been completed based on the maximum production capacity. Neither the tonnage nor the energy produced can be directly correlated to the potential odour emissions.
Q.4 The information states that odours are controlled by biofilter are not the products kept in tanks?
A.
- The liquid feedstock are kept in tanks, and when filled, the air that is displaced from the tank is treated by a biofilter.
- All solid material handling is done in a processing building that is under negative pressure. The exhaust from this building will be treated with the biofilter.
- Anaerobic digestion reduces the odour of the feedstock once treated. The treated product is a natural fertilizer to be applied to agricultural areas.
Q.5 Who determines odour levels and how?
A. The MOE establishes acceptable risk based criteria for acceptable limits of contaminants in the environment. Odour is considered a nuisance contaminant and is also regulated by the MOE.
Q.6 How are odours monitored and by whom? What is the process involved if there is a breach?
A. The Facility will be performing daily inspections. If odours are detected, the following steps will be put in place progressively until the odour is mitigated:
Confirm all odour mitigation procedures and best practices are followed
Ensure that the process building is maintained under negative pressure
Inspect outdoor facilities for spills or standing water
Inspect all piping, pumps, tanks, and other exposed equipment for cracks, leaks, etc.
Bio-En’s design and operating procedures have been developed with the intention of minimizing impacts to the surrounding community, however if there is a problem Bio-En will have a complaints procedure in place and will work with all stakeholders to resolve potential concerns.
Trucks (34)
Q.7 Does the average of 15 trucks include solid and liquid materials?
A. The average number of 15 trucks includes both solid and liquid materials. The Proposed AD Facility intends to accept both solid and liquid feedstock materials. The majority of feedstock material will be in a liquid form transported in sealed tanker trailers. Solid feedstock materials potentially include vegetable and fruit waste, energy crops (i.e., corn silage), and certain types of food processing materials.
Q.8 What is the impact if a truck with manure tipped over?
A. The impact will depend largely on proximity of material release to a sensitive receptor. Brokers and haulers of manure are now required to develop spill response contingency plans and provide training. The contingency plan must outline steps to:
Shut off source of release, if possible, to minimize amount of released material
Contain released material to minimize area of impact
Immediately notify Ministry of Environment Spill Response Hotline
Initiate clean up activities
Q.9 Will there ever be a back entrance to the Facility?
A. There are no plans to provide a back entrance to the Proposed AD Facility.
Q.10 One resident suggested larger site so that trucks don’t have to back up.
A. Backing-up of trailers is a normal component of industrial operations. A site layout and building design that entirely eliminates the need for backing-up of trailers is unfortunately prohibitively expensive and impractical.
Q.11 Will there be more than one truck on site at a time? Will they be kept inside as soon as they arrive on site or will they be kept outside for some time if there is more than one on site at a time? Are they cleaned before leaving?
A. There may be some overlap as one truck is leaving and another truck is arriving. Every effort will be made to minimize waiting times for all material transport vehicles.
Should any organic material or debris be on the exterior of trucks, it will be removed using a high-pressure hose before leaving the site.
Q.12 What are procedures when equipment fails? If the equipment fails and can not accept waste where will the trucks go?
A. Specific operating procedures have not yet been established for the Proposed AD Facility. A truck diversion plan will likely include steps to postpone any trucks that have not yet left supplier locations and, depending on the severity of the equipment failure and location of trucks enroute, trucks be returned or diverted.
Q.13 What hours will trucks be operating?
A. The Facility is currently proposing to have trucks arriving at the Facility between the hours of 6 am and 11 pm. The majority of trucks will operate between the hours of 7 am and 7 pm.
A. All trucks will be covered or sealed to minimize the potential for odours. Should any organic material or debris be on the exterior of trucks, it will be removed before leaving the Site.
Safety Related Questions
Q.15 What is the explosion hazard associated with the above pressures and what safety measures are in place to prevent explosion or fire hazards?
A. Similar to methane, biogas is flammable and there is an explosion hazard associated with these gases. Methane is potentially explosive at concentrations between 5 and 15 percent. The biogas stored under the membrane storages on the main digesters and the secondary digester and repository tank has a methane concentration that typically ranges from 50 to 80 percent. The gas generated during start-up or shutdown of the biogas can potentially have methane concentrations between 5 and 15 percent. A health and safety plan is being developed for the AD Facility in cooperation with the fire department.
Q.16 Concerned with methane toxicity/leaks.
A. There are no specific toxicology data for methane. Methane is very similar in nature to natural gas used in homes around the world. Methane is a simple asphyxiant, which acts to displace oxygen in the environment. Methane is neither considered to be nor suspected to be a cancer-causing agent (Methane MSDS). All tanks and buildings will be equipped with gas monitors and alarms to monitor methane and pressure levels, among other operational and safety parameters, to detect leaks.
Q.17 What security will be provided to the residents to assure them that they can use open flames when necessary?
A. Residents will continue to be able to use open flames on their properties in accordance with local bylaws.
Q.18 What control systems would be provided for residents to have in their homes in order to ensure their physical safety?
A. No control systems in the homes of residents are necessary to ensure their physical safety due to potential impact of Proposed AD Facility.
Noise (21)
Q.19 Concerned about generator noise, what measures are being implemented to reduce noise?
A. The engines are equipped with silencers and are kept inside the operations building. The Acoustic Assessment Report indicates that the modeled noise level from the Facility is below the acceptable MOE criteria.
Q.20 What are acceptable noise levels? Who determines them and how?
A. Sound level criteria are determined by the MOE based on the type of acoustical environment in which a Facility is located. Based on the land uses surrounding the proposed AD facility, the Facility will be located in a Class 2 Acoustic Area. The Maximum Exclusionary Sound Levels for Class 2 areas are 50 dBA between 7 am and 7 pm and 45 dBA from the hours of 7 pm to 7 am.
Suitability of Location (21)
Q.21 Is there another more suitable location rather than adjacent to town and residential homes?
A. The Proposed AD Facility is located in an industrial park that is not adjacent to any residential dwellings or residential areas. The location of the Proposed AD Facility is ideal for its purpose. Electricity connection capacity is a major hurdle in the development of Renewable Energy projects; this location is close to the electrical system and is located on a line that has the capacity to accept electricity.
Longer transportation and transmission distances result in lower energy delivery efficiencies, lowering the overall environmental benefit of the Proposed AD Facility. In addition, there are a number of potential industrial and commercial thermal energy customers in close proximity to the Proposed AD Facility.
Q.22 Will property value/property taxes of residents be affected?
A. Bio-En cannot comment on this due to the fact that property values and taxation rates are determined through market values and municipal mill rates. It is not anticipated that the development of existing industrial parcels will greatly influence residents already in proximity.
Q.23 Isn’t Bio-En concerned with the well being of neighbours?
A. Bio-En is a locally owned and operated company with strong ties to the community of Elmira, and is of course concerned with the well being of our neighbours. Bio-En believes that this project will be a great benefit to the community and the environment, supplying it with green energy and economic development. Bio-En would like to see Elmira become one of the greenest communities in Canada.
Air Contaminants
Q.24 My husband has genetic emphysema which means he has an intolerance to chemical discharges which is life threatening.
A. Bio-En can not comment on the specific health conditions of individuals, however, the Facility’s modeled emissions are well below the MOE health based POI criteria.
Q.25 Are the products of combustion of the biogas in the event that the flarestack is used harmful to my health, caustic, create property damage i.e. the burning of methane?
A. Biogas is very similar in composition to natural gas that is burned in houses and businesses all over the world. The emissions from this combustion have been conservatively estimated and potential ground level concentrations are well below the health-based criteria. These emissions are not caustic and will not cause property damage.
Q.26 What will be in the exhaust gas of the engines? How will the exhaust be handled?
A. Each engine will be equipped with a vertical exhaust stack. This will aid in the overall dispersion of the exhaust gases. The exhaust from the engines combustion will be very similar to that from natural gas combustion, and will be the products of combustion including: Nitrogen Oxides, Carbon Monoxide, Sulfur Oxides, Volatile Organic Compounds, Hydrocarbons, Carbon Dioxide and trace compounds.
Q.27 Request information on the air contaminants that will be emitted from the Facility, so residents can have better understanding of the odours/emissions to which they will be exposed.
A. Information on emissions and odours were submitted to the MOE for review through the Application for Certificate of Approval (Air). Under the new REA process, this information will be submitted in the ESDM. A draft of the ESDM was made available for public review on Bio-En’s website and at the public meetings.
Q.28 What portion of the gas will be composed of Methane/Carbon Dioxide/Hydrogen Sulfide?
A. The composition of biogas is approximately:
- Methane approximately 50 to 65 percent by volume
- Carbon Dioxide approximately 30 to 45 percent by volume
- Moisture approximately 0 to 5 percent by volume
- Nitrogen Gas approximately 0 to 3 percent by volume
- Oxygen approximately 0 to 1 percent by volume
- Hydrogen Sulfide less than 1 percent by volume
Q.29 CO2 can negatively affect respiration rates in humans.
A. CO2 is naturally occurring in the atmosphere and is produced from the respiration of organisms including humans. CO2 is generated from all fuel combustion including residential gas furnaces, gas stoves, barbeques and wood fireplaces. The CO2 generated by the AD facility will not impact levels surrounding the facility.
Q.30 Request peer review of air emissions data submitted with approval.
A. All data and supporting information will be submitted to the MOE for review.
Other Questions
General
Q.31 Provide a more detailed definition /explanation of the source materials.
A. Woolwich Bio-En Inc. (Bio-En) must secure the necessary approvals to build and operate the proposed anaerobic digestion (AD) facility before final details regarding the types of feedstock that will be utilized at the site will be known. Bio-En has been in discussion with multiple sources for different types of organic feedstock for the proposed AD facility, however without the necessary permits required to operate, securing contracts with these suppliers is not possible. It should be noted that the recipe of the organics digested at the facility would vary from time to time. Generally speaking, the types of materials which may be used at an AD facility may include, but are not necessarily limited to:
- Livestock manure primarily dairy slurry manure
- Energy crops such as, but not limited to, corn silage, switch grass silage, sweet corn silage and fruit pumice silage.
- Glycerol.
- Organic matter collected from restaurants and cafeterias.
- Source Separated Organics (SSO)
- Organic matter derived from the drying or cleaning of field crops.
- Organic derived from the processing of field crops.
- Organic matter derived from the production of ethanol or biodiesel.
- Aquatic plants.
- Organic matter derived from food processing at:
- Bakeries
- Confectionary processing facilities
- Dairies and facilities that process dairy products
- Fruit and vegetable processing facilities
- Cereal and grain processing facilities
- Oil seed processing facilities
- Snack food manufacturing facilities
- Breweries and distilleries
- Wineries
- Beverage manufacturing facilities.
- Brewers’ and distillers’ grain derived from food processing at breweries and distilleries.
- Fruits and vegetables.
- Organic materials from a greenhouse, nursery, garden centre or flower shop that is not part of an agricultural operation.
- Paunch manure.
Q.32 Will material be sourced from outside Ontario (ie. US or other provinces)?
A. There are no plans to source feedstock material from outside of Ontario. Bio-En also does not anticipate the need to do so in the future, however, availability of suitable locally sourced material will dictate the need to broaden the source area.
Q.33 What methane pressures will be formed in the digestion chamber and under the membrane?
A. The biogas reaches a pressure of approximately 0.15 psi under the membrane.
Q.34 Given there is no backup power to run the exhaust system to the biofilter in the event of a power failure how is the air in the process building going to be directed to the biofilter for treatment?
A. The Facility will use a portable back up generator in case of power failure. This generator will be used to power the building exhaust system, the biofilter and the agitators in the tanks.
Q.35 Concerned with spillage into land and creek, will there be secondary containment?
A. Bio-En will adhere to MOE and local township requirements for containment. The liquid storage tanks are being constructed in an area with secondary containment while the main digesters and the secondary digester and repository tank will be designed with a live load factor of 1.5.
Q.36 Will water from the creek be used?
A. No water from the creek will be used.
Q.37 What prime movers will be used to generate electricity? What size will they be?
A. The heat and electricity will be generated using reciprocating engines that are specially retrofitted to handle biogas applications. The Facility is proposing to have two (2) Engines, each with an output rating of 1426 kW electric with a heat output rating of 1510 kW of heat.
Q.38 What effects will be had on other infrastructure in the town?
A. Bio-En anticipates minimal impact on local roads and no impact on other infrastructure.
Q.39 How much water will be used?
A. The preliminary mass balance for the AD facility includes 12,600 cubic metres per year of fresh water from municipal and off-Site sources, as required. The amount of municipal water to be purchased will be minimized through recycling process water after start-up. Bio-En can recycle water used during the process, so the Facility may not require additional make up from municipal water.
Q.40 Will sewage treatment plant be contributor?
A. Sewage and septage will not be accepted or treated at the Proposed AD Facility.
Q.41 What process will be put in place to handle complaints once/if operational?
A. Bio-En will implement a complaint response program in conjunction with the MOE as outlined in the Design and Operations report submitted for public review.
Q.42 How can noise and odour study be done when no other facilities of this size exist? When will the reports be available?
A. The noise report summarized the expected Facility noise emissions based on manufacturer noise ratings and noise-modelling software was used to predict the noise impacts at sensitive receptors. The odour study was prepared using odour concentration typically found at similar operations. An air dispersion model was used with the estimated odour emissions and the stack parameters of the biofilter to predict off-Site impacts. All draft reports as required by O. Reg. 359/09 were posted on the Bio-En website www.bio-en.ca and were available at the offices of the Township of Woolwich and the Region of Waterloo 60 days prior to the second public consultation meeting.
Q.43 Why have the documents requested at the last pubic meeting not been provided?
A. Due to the changes in the provincial permitting of renewable energy projects, this project’s approvals were put on hold. The information requested has been provided as a part of the new Renewable Energy Approval process and can be found at www.bio-en.ca.
Q.44 How long will the digestate be stored on site? There should be a time limit.
A. The secondary digester and repository tank has been designed to accommodate 30 days of operation. This tank will be emptied by a third party hauler, the intervals of the emptying may vary however the digestate will be removed from the site at least every 30 days.
Q.45 Several members of the public are interested in other installations of similar facilities and technology.
A. There are several anaerobic digestion facilities of similar scale as the proposed AD facility under development or operating in Ontario, these include:
- Sea Cliff, Leamington 3.2 MW 110,000 tonnes per year (approved under SOP and 1.6 MW under construction)
- Storm Fisher, London 2.85 MW 195,000 tonnes per year (approved under SOP and construction pending)
- Storm Fisher, Cambridge 2.85 MW (proposed under FIT)
- Woolwich Bio-En, Elmira 2.85 MW 50,000-70,000 tonnes per year (proposed under FIT)
- City of Toronto, Dufferin facility 35-40,000 tonnes per year pilot plant operating successfully (planned expansion to 70,000+ tonnes per year)
- City of Toronto, new facility near airport 75,000 tonnes per year
- Kawartha Biogas, Havelock 9.8 MW (proposed under FIT)
In addition, there are several engines that burn biogas installed around the world, a list of GE Jenbacher engine installations is provided on the Bio-En website.
Lastly, Bio-En organized a tour to a biogas Facility in May 2010 for residents that expressed an interest during the public meeting or to Bio-En at other times.
Q.46 Concerned about lighting.
A. Design of the outdoor lighting plan has not yet been completed. Bio-En will minimize potential light pollution on neighbouring residents when developing the outdoor lighting plan.