Questions for Petmin, prepared by ACWW, for Town Hall 10.29.19 (many have yet to be answered)

 10.29.19 Petmin Plant ACWW 

  1. In the EPA’s Permit-to-Install, there are no requirements for on-site monitoring of any of the modeled air pollutants, but it states that existing monitoring stations in the county will be used.  Can you provide more details about where these  monitoring stations are, what they test for, and where that data can be found?
  1. Will EPA be agreeable to fenceline monitoring? 
  1. There should be complete transparency of The City agreement with Petmin as the citizens are “The City.” Where can the agreement between The City of Ashtabula and Petmin be found (tax breaks, what type of infrastructure The City is responsible, monies projected to be paid to The City, etc.)?
  1. The pig iron plant will pollute the local environment with nitrogen oxides, sulfur dioxide, greenhouse gases, volatile organic compounds and other waste products.  While the emissions levels have technically been approved by the EPA, the plant will still contribute hundreds of tons per year of toxic chemicals to our local environment.   Without the plant, we would not have to worry about polluting the air, land and water and could focus efforts on building on our strengths – like clean water for drinking, recreation, wineries, tourism? Don’t we, Ashtabula residents deserve more?
  1. How will the Petmin pig iron plant, and its release of greenhouse gases contribute to climate change? 
  1. The Permit-to-Install states that a third party will be capturing CO2 from the pig iron plant emissions.  Who is that third party?  Have they submitted a permit to the EPA yet?  When will they begin their operation?   As of 2/9/19 (air permit date) no application for the CO2 plant had been submitted.  Not sure if one has been submitted since then.  
  1. What are the specific VOCs (volatile organic compounds) that will be released by the Petmin plant?  
  1. Ashtabula Co ranks 68th out of 88 counties in terms of health outcomes ( Citizens of Ashtabula are asking The City of Ashtabula/Petmin to prepare a baseline health study as well as continuous monitoring/study after the plant is operational.  What plan is in place to monitor the health of inhabitants both prior to and after the plant is operational?
  1. What emergency plan is going to be in place for accidental pollution discharges into air or water?  Where can the public view this plan?  
  1. Petmin, a South African company, has received numerous environmental permit violations for its coal mining operations in South Africa.  Can we trust that Petmin will comply with its EPA permit here in Ashtabula?  What monitoring and enforcement is in place to ensure this?
  1. The pig iron plant proposes to use 15,000 million BTUs of natural gas daily (  This is more than double the consumption of every household in Ashtabula County combined, and is equivalent to the amount of gas produced from approximately #(need to find out) wells using hydraulic fracturing.  Natural gas for this project will come from Pennsylvania and be pumped to Ashtabula through the recently constructed Risberg pipeline.  The gas will be sourced primarily from high-volume horizontal hydraulic fracturing (fracking) in Pennsylvania, a process that has caused long-term health and environmental damage, including but not limited to permanent pollution of drinking water supplies, habitat destruction through construction of vast infrastructure networks, toxic pollution of land through leaking of open pit waste lagoons, toxic air pollution contributing to respiratory illness, and contribution to greenhouse gas emissions.  

Therefore, the Petmin project relies on natural gas produced in a way that is immensely taxing on the environment and public health.  We may think the consequences of fracking are out of sight and mind in western Pennsylvania, but wastewater from this process is being pumped into the earth here in any of 15 active fracking wastewater injection wells in Ashtabula County.  More wells will likely follow as the fracking industry continues to ramp up production since individual wells are becoming less productive and require more and more fracking fluid.  Basically, we are cheaply selling clean water from Lake Erie to the fracking industry in Pennsylvania only to have it severely polluted and then shipped back to Ashtabula County and injected into the earth where it puts our water and soil resources at risk of contamination and causes increased risk of earthquakes. 

So, do the economic gains anticipated from the pig iron plant outweigh the environmental and public health costs, including cumulative impacts from future development associated with the Riserg natural gas pipeline and interdependent industrial processes such as hydraulic fracturing?  What analysis has been done to answer this?  Shouldn’t we put a moratorium on this project until a comprehensive environmental impact statement has been drafted that assesses these cumulative impacts. 

12. The pig iron plant proposes to use 15,000 million BTUs of natural gas daily (  This is more than double the consumption of every household in Ashtabula County combined.  Much of this natural gas will likely be sourced from horizontal hydraulic fracturing, a process which is known to be highly damaging to the environment and public health.  Not only will the gas be sourced from toxic hydrofracking, but fracking waste is making its way back to Ashtabula County and being pumped into any of 15 active injection wells where it threatens to contaminate water and soil in our rich farmlands.  This raises the question of whether the economic gains anticipated from the pig iron plant outweigh the environmental and public health costs, including cumulative impacts from hydrofracking and future development associated with the Risberg gas pipeline, which seems to have been tailor made to this project and can pave the way for more local industries that consume fracked gas.  What analysis has been done to take into account these cumulative impacts?

  1. The smelting process to produce pig iron involves removing impurities including phosphorus, manganese, and sulfur.  Phosphorus contamination is a primary contributor to harmful algal blooms in Lake Erie.  Can you describe how phosphorus waste from pig iron production is collected and disposed.  What safeguards will be used to prevent phosphorus contamination of Lake Erie?
  1. The biggest argument in favor of constructing the pig iron plant here in Ashtabula is that it will create 110 permanent jobs and contribute $35 million (check this) annually to the local economy.  However, there are many (on 10.23.19 there were 23; employment vacancies at manufacturing facilities in the area, which offer the same type of factory-type work.  We know that the local economy is struggling in part because we cannot attract or keep young professionals in the area and that is in part because millennials are not attracted to factory jobs.  Given that we cannot seem to attract young workers to existing manufacturing job vacancies, why do we think younger workers will flock here to fill jobs at Petmin?
  1. Petmin is boasting this project as part of a manufacturing revival in this country and points out that manufacturing is a $33 billion industry employing 200,000 people nationally.  At the same time, the tourism industry employs 7.8 million people and earns $1.6 trillion dollars annually.  So not only is tourism a stronger industry economically, but it could also be leveraged to promote urban and environmental beautification and draw attention to protecting our most valuable natural resource, Lake Erie.  Would it not make sense to focus on promoting the tourism industry here in Ashtabula rather than a manufacturing plant that will contribute to air, water, and noise pollution?  
  1. How will slag byproduct, which contains impurities removed during smelting, be handled and disposed?  Where will it go?
  1. Based on modeling data in the air permit, hourly and annual emissions of nitrogen oxide gases exceed Significant Impact Levels, and hourly nitrogen oxide emissions exceed the typical EPA rule of being less than 50% of the PSD increment.  However, the EPA sometimes allows emissions up to 83% of PSD increments.  The hourly nitrogen oxide emissions from the plant were modeled at 70% of the PSD increment and therefore just squeak by under EPA standards.  However, there will be no on-site monitoring of nitrogen oxide emissions required.  How can we be assured that acute, hourly emissions of nitrogen oxides will not pose health risks to people living in close proximity to the plant?