Ethics & Lack of TRANSPARENCY
When asked about issues with their existing co-digesters,
Vanguard Renewables does not disclose the violations they have on record.
LET'S TAKE A LOOK AT VANGUARD RENEWABLES CURRENT AD1 CO-DIGESTERS
AND THEIR ENVIRONMENTAL & REPORTING VIOLATIONS:
Vanguard Renewables
AD1 CO-DIGESTER IN HAVERHILL, MA
Crescent Farms
75 Willow Avenue
Haverhill, MA
Environmental Violations
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As a result of their failure to construct a secondary control system to control potential hydrogen sulfide emissions, this resulted in numerous exceedances of their permit (see chart on p.5)
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52 permit violations for exceedance of hydrogen sulfide in 3 years, 8 months
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2/11/19-10/05/22
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In November 2021, part of the digester failed and released 51,309 cf of biogas into the environment.
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In March 2022, the facility released around 1.3 million gallons of digestate on ground surfaces adjacent to the operation.
FAILURE TO REPORT VIOLATIONS
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…for the period of 10/14/20 to 10/15/20, respondent failed to send an email to MassDEP stating that the facility had returned to compliance.
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For that day, hydrogen sulfide emissions were over twice (537 ppm) as high as the threshold (200 ppm).
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There have been numerous case reports of human deaths after acute exposure to presumably high concentrations (≥500 ppm) of hydrogen sulfide gas
FAILURE TO MONITOR/MEASURE EMISSIONS
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Inspection uncovered that the digester did not have a secondary control system for hydrogen sulfide emissions.
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Facility failed to produce any records of emissions for CHP and backup flares during inspection on 5/13/2021.
INACCURATE
DOCUMENTATION
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Facility failed to conduct a sound survey within 180 days of continuous operation of their combined heat and power engine generator which was required as a condition of their permit.
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Facility failed to conduct emissions testing within 180 days of continuous operation of their combined heat and power engine generator which was required as a condition of their permit.
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2018- MassDEP found during an inspection that the facility was operating an emergency engine for non-emergency purposes for 5,370 hours (which continuously would be over 7 months).
Fined $77,950 by MassDEP in 2022
Sources:
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https://fileservice.eea.comacloud.net/V1.4.0/FileService.Api/file/CETracker/ghgfjdgj
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Toxicology Report Hydrogen Sulfide: nlm.nih.gov
A review of the Vanguard Renewables Salisbury AD 1 annual air emissions 2022 report submitted to the State of Vermont lists air emissions for Vanguard’s co-digester on the Goodrich Farms site.
The Air Permit Application Waupaca AD 1: Project B22022402.01 submitted to the WI DNR (February 17, 2023) references the Salisbury Vermont as being similar to the proposed Waupaca AD 1 facility and uses data from that facility in estimating air emissions for the proposed Waupaca facility. It should be noted that the Salisbury facility is smaller than the proposed facility for Waupaca.
The below data suggests that the "Estimated Emissions Air Permit Application" for the Waupaca AD 1 would likely be significantly inaccurate. Please also keep in mind if the proposed co-digester were to be approved, there is no oversight from the DNR or EPA - it is all based on self-reporting which alone is a huge concern.
