April 19, 2010
The Honorable Dee Freeman
Secretary N.C. Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, NC 27699-1601
Dear Secretary Freeman:
In recognition of the numerous and serious adverse health consequences that can result from human exposure to the components of emissions of biomass burning, the North Carolina Academy of Family Physicians (NCAFP) is issuing a letter of concern regarding the development of biomass burning plants in the State of North Carolina.
Biomass burning of poultry litter and wood wastes creates emissions of particulate matter that research has shown increase the risk of premature death, asthma, chronic bronchitis, and heart disease. (1, 2) This burning process also creates numerous byproducts, including nitrogen oxides and volatile organic compounds that increase smog and ozone, which are known to increase lung disease and mortality (3); sulfur dioxides which also contribute to respiratory disease (4); arsenic which can increase the risk of cancer (5); mercury which can increase the risk of brain and kidney disease and effect the developing fetus (6); and dioxins which may increase the risk of cancer, heart disease, diabetes mellitus, developmental delays in children, neurotoxicity, and thyroid disease (7). These health effects would increase disability and death in all age groups, but particularly in the most vulnerable�developing fetuses, newborns, children, those with chronic illness, and the elderly. As a result of this increased disability and disease, medical costs in the state will increase.
One of the reasons for encouraging renewable energy through legislation like the North Carolina Clean Smokestack law was to provide cleaner air for citizens. However, there is concern that burning of poultry litter may result in similar or greater emissions of nitrogen oxides, particulate matter, carbon monoxide, and carbon dioxide to coal- burning plants (8). The NCAFP requests that the North Carolina Department of Environment and Natural resources strongly consider the potentially harmful consequences to the health and wellbeing of North Carolina citizens when contemplating the permitting of biomass burning plants in the state.
With best regards,
R.W. (Chip) Watkins, MD, MPH
President, NC Academy of Family Physicians
Letter from local physician in NC:
I'm a physician in a rural North Carolina community where a company, Fibrowatt, that would burn poultry litter to create electricity, proposes to locate. I write in response to an interview printed in the December issue of American Recycler where a vice president of Fibrowatt explained to an American Recycler reporter a number of benefits from burning poultry litter in Minnesota at their flagship plant, Fibrominn.Specifically I wanted to respond to what was not mentioned in the article.
The vice president of Fibrowatt said,"We are regulated by federal and state environment regulations and pass all requirements. We use best available technology." He also said that, "The plant meets strict air emission limits for each of the major gasses. Emissions are regulated and monitored by a continuous monitor system." What he neglected to tell the reporter was that at the time he was being interviewed for this article, Fibrominn was under Open Enforcement Action from the Minnesota Pollution Control Agency for violations of their Minnesota Air Permit. They had been out of compliance with the EPA for 6 out of 12 quarters according to the settlement below, and they were noted to have excess emissions of three major gasses and of particulatematter. Additionally, they were cited for continuous monitor downtime. In December (the same month ofpublication of his comments about being in compliance) Fibrominn was fined $65,000 by the Minnesota Pollution Control Agency for multiple violations of their air permit.Fibrominn Violations List, 12/18/09:�Late HCL testing. �Late PM10 testing. �Late mercury testing. �Late CEMS Relative Accuracy Test Audit.�Missed pressure drop range proposal. �Missed Testing Frequency Plan. �Missed Performance Test Report.�Missed Semi-Annual Deviation Reports. �Missed Compliance Certifications. �Missed Monitor Downtime Report. �Missed Silt Road Loading Measurement Report. �Continuous Monitor Downtime.�Failed performance test-total particulate matter. �Excess NOx Emissions. �Excess SO2 Emissions. �Excess CO Emissions.�Failure to Self-Report Deviations.The Fibrowatt vice president also failed to mention: �Fibrominn was required to purchase and install at least $80,000 worth of new emissions control monitoring equipment.�Fibrominn never admitted that they violated their permit.�BACT or Best Available Control Technology only means that the technology is that used by the 12 percent best companies with similar operations. BACT doesn't guarantee anything about effectiveness.�While Fibrowatt was under Open Enforcement Action local physicians and citizens were not notified of the emissions violations.�That the farmers in North Carolina will be spending more for fertilizer if poultry litter is burned rather than being creatively applied to crops.�That these plants are far less efficient at creating electricity and the cost of electricity to citizens goes up.�Biomass burning is dirtier than coal in many respects.�Millions of dollars worth of nitrogen is lost into the air in the burning process that creates nitrogen oxide and volatile organic compounds that in turn creates ozone and smog that would increase lung disease.�Industrial fertilizer is more likely to run off than organic fertilizer.�Fertilizer made from the bottom ash of the incinerator would contain the heavy metals and some arsenic in poultry litter and it would be put right back on the soil but in a concentrated form and be more likely to run off.�Analysis of bottom ash from the Fibrominn in 2007 revealed arsenic in the ash when citizens had been told that there was no arsenic in the chicken feed.�Replacing nitrogen lost in the burning process could increase American dependence on foreign nitrogen.I'm not a farmer but farmers are my patients, and my patients would also like to note that the vice president didn't mention that:�42 other physicians and 11 pharmacists in our county have signed letters of objection to poultry litter burning due to increased health risks to our families and patients.�75 percent of vineyards owners in the Yadkin Valley signed a petition against Fibrowatt and many farmers are against the plan.�That a poll of the two county area demonstrated that of those who answered, the majority were against this sort of industry.�Though the Fibrowatt spokespersons likes to point out to potential customers that their process passes the "sniff test" and that they produce little smoke, most of the toxic emissions from this plant are colorless and odorless.�A study at UNC Chapel Hill entitled "Waste to Energy Conversion: Potential for Environmental Injustice" characterizes the burning of poultry litter as a form of environmental injustice since rural citizens have many of the problems that would be worsened by Fibrowatt emissions.�The letter to the Minnesota Pollution Control Agency that pointed out that their plant was emitting 7.5 times the amount of particulate matter than their permit allowed.�Particulate matter increases the risk of premature infant death, asthma, chronic bronchitis, heart disease and stroke and affects our children, athletes, old folks and those with chronic diseases the most.�Dioxins would be produced by this plant as an "unwanted but necessary" byproduct of the process. Dioxins are among the deadliest man-made chemicals. They are listed in the dirty dozen alongside DDT. Both the EPA and the World Health Organization recommend stopping dioxin production at the source. There is no known level of dioxins that don't put a human at increased risk of cancer.�The main source of dioxins is incineration of hydrocarbons in the presence of chlorine. Poultry litter is laced with chlorine from antibiotics in the poultry feed.�Dioxins in minuscule amounts (parts per trillion) increase the risk of immune deficiency, neurotoxicity, developmental delay, hyper and hypothyroidism, polycystic ovary disease, endometriosis and affect the fetus, newborn and children the most.�A study demonstrates that in rural areas where people eat locally grown beef, eggs, milk and fish, dioxins levels in humans increase up to 20 percent in the first two years around incinerators that produce dioxins.�Pelletizing, broadcasting, deep introduction of poultry litter into the soil or digesting poultry litter does not produce dioxins.�There are a host of other emissions from a plant that burns poultry litter including hydrochloric and sulfuric acid leading to acid rain, sulfur dioxide (more particulate matter), carbon monoxide, and others.�Their plant would burn up to 40 percent woody biomass from wood waste.�Their plant accepts wood waste from Minnesota and five surrounding states.�Recent studies debunk the myth that biomass burning is carbon neutral.�A study in 2007 identified their three original English plants (that the vice president referred to in the article) as being among the top 100 dirtiest plants out of over 2000 power plants in the entire United Kingdom.Farmers and physicians need every grain of horse-sense our parents and grandparents bequeathed us to protect our children and grandchildren from investors like these who don't live in our community and who will never eat our food or breathe our air contaminated by toxic emissions from plants like these.Signed:William Blackley, MD, Fellow AmericanAcademy of Family Practice and CitizensAlliance for a Clean Health Economy� The Surry County Chapter of the BlueRidge Environmental Defense League
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