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Do the Math

The Science Behind an Industrial Polluter in Jefferson County

What would you risk for Rockwool?

Science is never certain. It’s all about probabilities and risks. We know from decades of research that the predicted outcomes of a warming planet, including droughts, floods, disease, famine and war, are severe. Scientific models can’t forecast the precise timing or location of any event, and scientists are generally reserved in their statements, so the public passion of climate scientists and the strong language in recent reports should be alarming.

We also know that fossil fuel consumption is the primary cause of climate change, which is why fossil fuel interests use the uncertainty that forms the foundation of science to create skepticism. It is possible to rapidly shift to a post-carbon civilization with economic gains and greater prosperity for everyone, except the oil, gas and coal companies. For fossil fuel interests, decarbonization is an existential threat.

As Bill McKibben put it in a groundbreaking 2012 Rolling Stone article “…we need to view the fossil-fuel industry in a new light. It has become a rogue industry, reckless like no other force on Earth. It is Public Enemy Number One to the survival of our planetary civilization.” McKibben’s answer was divestment from fossil fuel companies and he created 350.org to pursue that end.

The fossil fuel industry is taking one last shot at humanity before the extraction and consumption of coal, oil and gas are ended forever. In Jefferson County, WV a planned Rockwool mineral wool factory would consume 84 tons of coal a day and emit over a hundred tons of pollution each year into the air of a county that currently absorbs just just 18 pounds a year.

Hazardous pollutants and toxic chemicals are by definition unsafe. The release of thousands of tons into the atmosphere is concerning to residents and primarily benefits the emitter, the local water utility and the fossil fuel industry that would supply fracked gas and about 84 tons of coal a day. The only solution to avoiding the emissions is to stop the construction of the plant, which is as threatening to a manufacturer as the “keep it in the ground” movement is to fossil fuel interests.

In each case, activist citizens pose an existential threat to a corporate interest, which in turn poses an existential threat to the citizenry. It appears to be a standoff.

Earlier this week, State Senator John Unger, whose district includes Jefferson County, introduced a bill that will require public meetings in the areas impacted by any air or water permits, which should help for future issues, but is too late to impact Rockwool. The Rockwool air permit hearing was held in Charleston, WV, a five and a half hour drive from Jefferson County and emails were distributed to only the standard email list that received all notices.

An analysis of the the email distribution group shows why there was little public comment on Rockwool’s air permit application. The notification to the Sierra Club went to a legal assistant whose primary job was soliciting interns for an Oakland, CA environmental law program. She is no longer with the Sierra Club and emails to the address listed bounce. The Nature Conservancy emails went to a generic account at headquarters (tnc@tnc.org), Appalachian Mountain Advocates focuses on mountain top removal and pipelines, so they would not be interested in a stationary source manufacturer in the eastern panhandles, West Virginia Rivers is also based in Charleston and Appalachian Voices advocates against pipeline compressors from it’s headquarters in Boone, NC. The remaining non-profits are pro-business, such as the WV Municipal League, WV Surface Owners Group for oil and gas rights and the state building rights council. Most of the email recipients were service providers looking for opportunities to contract with developers.

Because heavy industry wasn’t planned for the county or any municipality, and the public officials promoting the project were not even aware that Rockwool was a heavy emitter, Jefferson County citizens and watchdog groups were not alerted. It wasn’t for a chance encounter between a conservative Republican and an environmental activist, the nature of the development might not have been revealed until after the factory was operational.

It’s hard to imagine stranger bedfellows than Chris Kinnan and Mary Anne Hitt. Kinnan, now a cloud systems software architect, had served over a decade ago as an executive for FreedomWorks, a right-wing think tank and advocacy organization promoting “free markets and individual liberty” through “less government, lower taxes, and more economic freedom” and on the staff of Dan Miller, a conservative Republican congressman representing Florida’s 13th district.

Hitt is the director of the Sierra Club’s Beyond Coal Campaign where she works “to eliminate the pollution caused by coal throughout its life cycle and repower the nation with clean energy.” The two were chatting in passing at the pick-up/drop-off area of the daycare attended by their young children. Chris asked Mary Anne if she’d seen the article in the Martinsburg Journal about the groundbreaking for the Rockwool factory. After the article was published, Chris and some others had gone online and looked up the PSD permit and realized there was a big, serious list of pollutants.

“This has a PSD permit?” Hitt responded in surprise. She knew those were only issued for major sources of pollutants. She contacted Al Armendariz, Deputy Regional Director of the Sierra Club’s Beyond Coal Campaign, who used to work for the EPA leading the Dallas-based Region 6, and asked, “is this really bad or does it just look bad?” Armendariz’ response was, “it might not be the most polluting factory in the world, but you definitely don’t want it right across the street from an elementary school. The formaldehyde, in particular, is of concern. The closer to the source, the worse the impact on health.” The volume of PM 2.5 was also concerning, given the long-term impact on the cardiovascular system. With four schools within 2 miles of the site, housing 30% of Jefferson County’s public school population, the risk of potentially chronic and debilitating or even fatal illness was likely to be unacceptably high.

Armendariz, in turn, contacted Regina Hendrix, the Eastern Panhandle coordinator for the West Virginia Sierra Club and helped her draft the July 2, 2018 letter to the DEP that got Matt Ward’s attention and activated the flood of members joining the CCARR Facebook group.

I asked Hendrix how the Sierra Club missed the initial PSD application and public comment period. Her answer was revealing.

“I came from Charleston ten years ago because I didn’t want anything to do with mountaintop removal anymore. I was tired of fighting. I just never thought they would try to put something so awful in our midst.” Even though mountaintop removal was destroying people’s communities and poisoning the water, it was hard to get 50 people to turn up for a hearing, public comment or protest. People were just too beaten down.

Hendrix never imagined the state would kill their golden goose. “We pay more than any other county as far as taxes. Why would they want to pollute us when they need our taxes to treat the abandoned mine sites, and to pay for medical clinics in the cancer clusters? I never thought they would do that.”

“It always amazed me the 2014 water crisis in Charleston,” she continued. “300,000 people on one water intake into on the Elk River. The reason is that wells in Southern West Virginia became polluted with coal waste injected underground and travelled underground.” She would drive past the Freedom Industries site that contaminated the Charleston water supply, see the tanks grown over and rusted out and know it was only a matter of time before a catastrophe occurred. The site was only a mile and a half above the intake for the Charleston water supply.

According to Hendrix, in Jefferson County a leak or spill would be worse. There’s no point source of water to clean up. Eighty percent of the county is on well water tapping into underground aquifers.

A few months ago, Hendrix received an anonymous letter with two pictures from the Rockwool Mississippi plant and one from Rockwool’s plant in Milton Ontario claiming to show illegal storage. She hadn’t published them because they weren’t verified, but if accurate they were disturbing. Chemicals are not allowed to be stored on the ground, and one showed runoff.

Hendrix was particularly annoyed that Rockwool continually cited the Sierra Club as an organization that “approved” the mineral wool standard. She called that an outright lie. The Sierra Club provides input to negotiate the strictest limits possible, but she doesn’t believe they adequately protect human health, and each project needs to be judged and challenged individually.

Hendrix believes that over time the Eastern Panhandle will have more influence in Charleston as people continue leaving the coalfields and travel out here. She regrets not being aware of the application and acting faster. She mentioned that the West Virginia Sierra Club doesn’t have the resources of Maryland, Pennsylvania and Virginia, which monitor filings more closely. She also doesn’t know if it would have made a difference. The Sierra Club could have sued earlier to try to stop the air permit, but the application itself was clearly a rushed job designed to meet a “technical standard” that had no bearing on the environment or health, so there wasn’t necessarily a basis for challenge.

At 82 years old, she didn’t think she would have another major fight, but feels energized by the community support. Hendrix not surprised to become a direct target of Rockwool, who characterized her as a threat in a widely mocked Facebook post and is working with Justin Raines, the Sierra Club’s WV Chapter Director, to combat what Raines characterizes as a “deliberate misinformation campaign.”

On Rockwool’s website it states, “In the United States, stone wool manufacturing is strictly regulated by federal standards set by the EPA. These standards, known as the Maximum Achievable Control Technology (MACT) standards, were most recently updated in 2015, based on a robust scientific process, with direct input from the Sierra Club.” Michael Zarin, a spokesman for Rockwool, often takes this a step further by stating, as he does in this tweet “Ranson emissions will be way below limits even the Sierra Club agreed were safe” and in the following statement addressing the concerns of Maryland residents, “our emissions will be well below levels even the Sierra Club in its 2015 lawsuit against the EPA accepted as being safe for sensitive populations such as children, the elderly, and asthmatics.”

When Rockwool claimed in a Facebook post that “the Sierra Club was party to the EPA rulemaking process that led to additional emissions limits being placed on mineral wool manufacturing,” Raines responded with the following:

"I'm the Chair of the West Virginia Chapter of the Sierra Club, and I'd like to repeat my request that you stop using the Club's name in your deliberate misinformation campaign.

As both the Rockwool Corporation and its many (but ever-declining) surrogate politicians have been repeatedly informed, the Sierra Club makes comments on and tries to improve every single major environmental regulation which goes before the US government. Our participation in the comment period for wool mineral standards in no way means the Sierra Club controlled those standards, approved those standards, or endorses those standards. Your continued abuse of our name is akin to saying the citizens of Jefferson County were a party to Rockwool because they spoke against it at a County Commission hearing.

The WV Chapter of the Sierra Club stands firmly opposed to your toxic facility, doubly so for its endangerment of nearby schoolchildren, and in no way considers Rockwools emissions to be anything even resembling safe or acceptable! Thanks for your cooperation in ending the abuse of our good name!"

A blog post from Mary Ann Hitt at the time of the EPA hearings shows that the Sierra Club was not pleased with the outcome.

At the outset of his “damage control” memo consultant Matt Ward framed the critical topic for his client the Ranson city government: “The only really significant issue is – will public health be protected by the Rockwool Clean Air Act permit?” Based on the DEP’s response to the Sierra Club letter, the answer appears to be that there is no way to know.

Dr. Michael McCawley, the foremost expert on environmental health sciences in West Virginia, agrees.

“In toxicology we are fully aware that it is the dose that truly makes the poison. In this case we do not know the dose yet,” McCawley said. “Therefore, we cannot say with any certainty what the level of alarm should be.” The exact health effects of the pollutants are affected by interaction between the emissions, the weather and the terrain. “The air permit does a poor job of answering the issue,” he said. “So there is no wonder that citizens are in an uproar.”

Tim Ross, a native West Virginian, 20-year resident of Jefferson County and retired National Weather Service meteorologist with over 38 years of federal service, has revealed critical flaws in the Rockwool air dispersion model referenced by DEP. According to Ross, the EPA requires one year of onsite measurements or the application of historical data from remote monitoring stations in a model that produces results equivalent to a year of monitoring. The most significant issue in Rockwool’s dispersion model is that little evidence was provided of any correlation between the monitoring sites used and the planned Ranson factory site. The local conditions were simply disregarded.

Zarin noted to the Frederick Post that it’s important to distinguish between the volume of emissions that come out of the chimney stacks and the concentration of those emissions at ground level. “The two are related but it’s the latter that determines the health and environmental impacts,” Zarin said. (Zarin, on behalf of Rockwool, declined to comment for this article).

Ross states that, given the local atmospheric effects, the Rockwool smokestacks will be “like a hose shooting straight up in the air and raining the toxic and hazardous pollutants directly down on the local communities.”

The air is calm a greater percentage of the time in Jefferson County than in the monitoring locations used in the Rockwool model submitted to the DEP, and the Potomac Highlands Valley that would house the proposed site features “temperature inversions” that trap pollutants near the ground. Based on peer-reviewed meteorological studies, Ross estimates that temperature inversions occur about 30% of the time in the greater region of the site, increasing to 50% in the winter.

The Great Smog of 1952 that settled on London caused 4,000 deaths in three days and sickened over 100,000 people was caused by a temperature inversion. About 6,000 more died in the following months according to recent research.

The common sight of tight, thick carpets of cloud stretching across the fields of Jefferson County that have long been considered a beautiful feature of our landscape now appear ominous and foreboding to many residents.

Closer to home, the 1948 Donora Smog was an air inversion that killed 20 people and sickened 6,000 of the 14,000 residents of Denora, a town in Pennsylvania on the Monongahela River that borders West Virginia. Mortality rates remained significantly higher for a decade than those in surrounding communities.

Dr. Michael Glenn, the retired director of the USDA-ARS-Appalachian Fruit Research Station in Jefferson County, WV with over three decades of experience in weather measurement and interpretation also argues against the frequent claim that there is a correlation between the environmental and public health impact in Jefferson County and the communities surrounding the Rockwool plants in Byhalia, Mississippi and Milton, Ontario. Those plants are subject to consistently strong steady winds that blow pollutants away from population centers. Byhalia benefits the Gulf of Mexico generating air currents from the south and Milton from the Lake Erie effect blowing wind to the west.

The permit was granted by the DEP based on the determination that the pollutants are likely to be dispersed over large areas rather than concentrated in close proximity to the source. This determination is not borne out by the model.

Jay Mansfield, a retired clinical and research support systems engineer who lives in Jefferson County, says that “diseases are not caused by tons of pollutants, they’re caused by molecules.” With a background in chemistry, human physiology and information management, Mansfield has developed infectious disease models for the Department of Defense, including an early notification system for community-based epidemics deployed worldwide in response to 9/11, and served as an assistant plant chemist for Roadmaster early in his career. He studies bus routes, dispersion models and toxicology tables, applying his skills to understand the probable dosage of toxins and hazardous pollutants from the plant received by vulnerable populations and the general public.

With 3,356 children in the five schools in close proximity to the planned Rockwool site, Mansfield estimates 2.4 million exposure days in the 12 years it takes to matriculate through the system. The 8.3% of the population estimated to have asthma will suffer a mandatory 200,000 days of exposure. Children are more sensitive to pollution than adults, and asthmatic kids can be triggered into a full-blown asthma attack with only a small dose of airborne pollutants. Mansfield estimates that Rockwool will increase pollution levels by 20,000 to 30,000 times the 2017 values. Mansfield provided a list of the major pollutants and the associated health impact.

McCawley explained to the Martinsburg Journal that the response the human body has to these regulated chemicals can come in the form of inflammation and the severity varies based on exposure levels, “The body produces chemicals in response to irritations, like a bug bite, and in doing so can cause inflammation to occur,” he said. “The problem with inflammation is that it is the basis of almost all chronic diseases like heart and lung disease, but it can also greatly affect those that suffer from asthma and other problems.”

In addition to diseases caused by inflammation, McCawley says the permitted volume of VOCs and particulate matter support the public’s concern. “The VOCs are one of the primary sources of cancer risk, especially benzene,” he said. “The VOCs, however, are not usually counted among the National Ambient Air Quality Standard criteria air pollutants. Among the NAAQS pollutants, the particulate matter would pose the highest cancer risk, all things being equal, though possibly not have as high a potential as VOCs for potency as a carcinogen.”

Jefferson County family physician David Didden agreed that the risks associated with the operation of the Rockwool plant far outweighed any possible benefits. “When you step back if you’re really paying attention and you look at the net effects of a plant like a mineral wool production facility i can’t imagine you being in favor of it when you consider the overall effects.”

Health concerns are not limited to air pollution, and the water infrastructure plans appear similarly opaque. When the DEP held a public hearing last month in Ranson on the application filed by the Charles Town Utility Board (CTUB) for sewer service several speakers, including John Maxey of the Blue Ridge Watershed Coalition (BRWC) expressed confusion and skepticism about the discharge plans. The BRWC has been performing independent water quality monitoring for six years on nine different tributaries with a focus on stormwater management and implementing a septic tank program. Rather than reporting violations to the health department, the BRWD arranges 0% interest loans for septic systems and works closely with agriculture and industry on solutions.

In 2009 the EPA put goals in place for water contributions of nutrients such as phosphates, nitrites and e-coli to the Chesapeake Bay watershed and the Shenandoah River is a major contributor to the TMDL (total maximum daily load) due to generally poor stormwater management. Rockwool is permitted to draw 500,000 gallons a day from the Jefferson County aquifer but anticipates discharging 46,800 gallons a day into the treatment, which is about enough for toilets and other use, not industrial wastewater, through Evitts Run into the Shenandoah. According to the testimony, increased discharge could cause the EPA to put expensive mandates in place that would restrict growth and decimate county budgets.

The Charles Town wastewater treatment plant is near capacity. Chlorides the Rockwool's water softening system may interfere with the nutrient removal process in the treatment plant by making the environment unsuitable for the bacteria to effectively remove waste. If Charles Town loses its ability to remove nutrients from its waste stream the city could face enormous costs to upgrade and additional penalties.

The planned Rockwool factory site is in the vicinity of the densest sinkhole area in the region.

While releases into the Chesapeake Bay watershed through surface water is a concern, a more pressing issue for Jefferson County residents is the risk of well-water contamination. Jim Cummins, a resident of Jefferson County and the retired Director of Living Systems at the Interstate Commission on the Potomac River Basin, an organization chartered to protect the drinking water of Washington, DC, characterizes the development in stark terms. “Rockwool could not have selected a more vulnerable site,” he writes.

80% of Jefferson County residents are on well water. The underground aquifers make the area particularly vulnerable to contamination from chemicals. Remediation is almost impossible.

The area was called the Arabian Plain by settlers due to the lack of surface water. Underground aquifers rapidly distribute water throughout the county’s karst geology. Sinkholes are prevalent in the vicinity of the planned Rockwool site, and the company has been admonished by the DEP for failing to report them before beginning remediation. The unstable geology caused a 2008 sewer trunk line failure that could have been catastrophic if it had not been rapidly detected.

Stream map shows how Jefferson County includes the "Arabian Plain," an area where most water flows in underground aquifers making remediation in the event of contamination impossible.

In 2014 Freedom Industries spilled chemicals into the Elk River threatening the Charleston, WV water supply that served 300,000 people for a week. Because the municipal water system was served by surface streams and rivers, the spill could be cleaned and service restored. If something similar occurred in Jefferson County, decontamination of the groundwater would take hundreds of years. With 80% of the county on well water, Cummins writes, “the public health risks from such events are hard to overstate for they can easily and rapidly spread pathogens underground over a broad landscape in Jefferson County that is dense with drinking water wells. This can cause widespread illnesses which could be fatal, especially to infants, the elderly and those with suppressed immune systems. It would be an emergency response nightmare. Remediation measures at best would be long term and expensive.”

In a recent public Facebook post, Hendrix shared a piece written by Alex Cole, an organizer for the Ohio Valley Environmental Coalition. He wrote, “other people know where I live as Chemical Valley, and I see it that way, too. Many of the people in that cemetery ended up there with cancer after years of working for Carbide, Dow, FMC, Monsanto, Ambrosia, DuPont, Bayer, ClearOn, or Chemours… pick your poison, any one of the ever-changing names upriver in Charleston is likely to kill you.

Those names poisoned the river and no one alive remembers a time when it was clean. We can’t eat the fish, the poison has seeped into the groundwater in the bottoms, and now city water is piped in 40 miles, all the way from the Elk—if you can even trust that.”

In response, Hendrix asks, “Do we really want to be in a place where you can’t swim in the Shenandoah and you can’t eat the fish you catch?”

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