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“Hey, what’s that white stuff?” By Tammy L. Endlish, Endlish Environmental
Once people find out that I am the environmental consultant for Huron Lime, they invariably want to know “what’s that white smoke?” My response is “what white smoke?” Of course they are referring to the white steam plume that is generated when limestone is heated to 1500 degrees Fahrenheit to separate the lime (calcium oxide – CaO) from the limestone (calcium carbonate -- CaCO3) releasing carbon dioxide, water (steam) and some lime dust. As much as the company would like to be able to recover 100 percent of the lime produced, it is not yet technically feasible. “But isn’t that lime dust harmful?” I can answer this question thanks to my educational background in Environmental Health and more than a decade of working for the Ohio EPA. But first a little regulatory history, if I may. In 1970, President Richard Nixon signed the Clean Air Act into law which required the U.S. Environmental Protection Agency (EPA) to identify and set standards for pollutants identified as harmful to human health and the environment. These six criteria pollutants are carbon monoxide, nitrogen dioxide, ozone, sulfur dioxide, particulate matter (eventually limited to the respirable kind which is less than 10 microns in size) and lead. These standards are called the National Ambient Air Quality Standards (NAAQS) and set limits to protect public health and the environment. States could adopt more stringent standards and limitations and Ohio did (rivaling California in its environmental protection). Therefore, it can be said with confidence that if a company is operating in compliance with the requirements and emission limitations of Ohio EPA, they are not a threat to public or environmental health. Huron Lime does indeed comply with all U.S. EPA and Ohio EPA emission limitations as demonstrated during periodic stack performance tests which are conducted by a licensed testing firm and witnessed by representatives of Ohio EPA. “But isn’t Huron Lime grandfathered from complying with some requirements?” Yes. Any air contaminant source installed prior to January 1, 1974 is exempt from the requirement to obtain a permit to install (PTI) and meet best available technology (BAT) requirements. Huron Lime was installed in 1966 and was not required to have a PTI for the kilns. Other operations at the facility are subject to the new source review requirements and have the required permits. However, Huron Lime was still required to obtain a permit to operate (PTO) and comply with pollutant-specific emission limitations. The emission limitations, as mentioned earlier, are based on protecting public and environmental health. There are larger lime producers in Ohio which legally emit even more dust. Huron Lime has demonstrated compliance with all emission limitations and actually emits much less than what is allowed through the use of their wet scrubbers which collect lime dust as the air stream travels from the kilns to either stack. If any of the scrubbers malfunction, Huron Lime is required to halt production in that kiln. The Clean Air Act was amended in 1990 and added Title V. Title V requires all sources of air contaminants which emit (1) 100 tons/year or more of particulates, sulfur dioxide, nitrogen oxides (NOx), carbon monoxide and organic compounds each, or (2) 10 tons/year or more of any individual hazardous air pollutant (HAP), or (3) 25 tons/year or more of combined HAPs) to obtain a special type of PTO called a Title V operating permit and to pay higher fees based on actual emissions. The beauty of this fee system is that it rewards a company financially for reducing their pollution. Huron Lime is a Title V facility and has complied with all requirements of this program as well. “Isn’t Huron Lime getting off easy by being grandfathered?” Not at all… U.S. EPA continually adds new standards including the federal Maximum Achievable Control Technology (MACT) for Lime Producers. In 2006, Huron Lime voluntarily applied for a PTI (even though they are grandfathered) requesting emission limits and voluntary operational (production) restrictions that are stricter than what they were required to comply with to be categorized as a minor source with respect to the MACT standard. Unfortunately we are all aware that just because a company complies with all required emission regulations and is not going to harm public or environmental health, it can still be annoying. In accordance with OAC rule 3745-15-07, no industry is allowed to cause a public nuisance. Ohio EPA has received some complaints about lime dust on private property when the wind direction shifted and resulted in the plume heading over some nearby residences. In response to those complaints, in the 1990’s Huron Lime increased the height of the stack which allowed better dispersion of the dust so it was not heavily concentrated in one area. “Could Huron Lime be relocated?” No. Huron Lime relies on Lake Erie to receive limestone via ships. The stone comes from the upper peninsula of Michigan. This stone is desirable because it has a higher calcium content than limestone sold in Ohio which better meets the needs of the end user. “How will Huron Lime impact the development of the ConAgra property?” This is where facts get mixed up with opinions and since you asked my opinion (ok you didn’t but you’re reading this, right?) I am happy to answer. The concern should be, “how will the development of the ConAgra property impact Huron Lime?” There is no question that the proper development of the ConAgra property will be a bonus for the City of Huron. But it is not in Huron’s best interest to develop the site in a manner which will hurt Huron Lime. Huron Lime provides much-needed tax revenue to the city and employment (income and more tax revenue) for citizens who live in Huron and the surrounding areas. In addition, Huron Lime provides lime to the steel industry which is the hub of all American industry. Not much can be made without steel either as a constituent of the product or in the machinery used to create products. In addition, lime is used to improve soil quality for area farmers and as a constituent in water and wastewater treatment. Given the nature of the lime industry, certain ideas for the development of the ConAgra property could be problematic. Condos could be built but as the folks who bought the condos in Sandusky overlooking the Sandusky Dock Corporation have discovered, condos and industry are not a good mix even with a beautiful view. Ditto for shops or a fancy marina. In my opinion, the most practical development idea would be another industry, with low pollution, which would bring much-needed jobs to the area. May I wax poetic? Huron Lime is part of Huron’s identity. From the top of the Space Spiral at Cedar Point, I can easily use the plume to find Huron. The steam plume guides boaters safely back to Huron as well as the lighthouse (and is also a good indicator of wind direction). My family enjoys walking along the pier and watching the ships come in to unload limestone (followed of course by a trip to Pied Piper). And when I return from traveling east or west on Route 2, Huron Lime is a beacon, letting me know that I’m nearly home. Thank you for the opportunity to share some thoughts on Huron Lime and hopefully answer any questions you may have had. |