2012-10-12 Regarding Formosa Petrochemical Corporation’s application for an appeal against a decision made at the 219th EIA meeting, the Yunlin County government has suggested that the EPA reject the application as controversial issues concerning public health and pollution emissions are involved.

According to Resolution No.4 of the 219th EIA meeting in the Seventh Analysis Report on the Difference of the Environmental Impact for the fourth stage of expansion of the sixth naphtha cracker plant passed on July 25, 2012 by the EPA, VOC emissions from combustion towers (including abnormal emissions), paints and coatings, cooling towers, storage tank cleaning activities, and maintenance, repair and overhaul will be included in the calculation of the total emissions of the sixth naphtha cracker plant, and the methods of checking and verifying are finalized and included in the minutes of this meeting. However, Formosa Petrochemical Corporation issued a letter (Letter No. 101426) on August 9, 2012 and submitted an application for appeal against the aforementioned resolution made by the EPA. At the 221st EIA meeting on September 7, 2012, this issue drew heated discussions. Yunlin County’s EPB would like to provide the following information and explanations in response to concerns and questions about the meeting:

(1) According to Item 2 in Article 21 of the Air Pollution Control Act, the central competent authority shall determine regulations for the calculation, reporting content, procedures and methods, checking, and other binding matters for the annual air pollutant emissions quantities of stationary pollution sources. In addition, according to Article 21 of the Stationary Pollution Source Installation and Operating Permit Management Regulations, for a stationary pollution source that is required to implement an environmental impact assessment, the permit content shall include the approved environmental impact statement, an assessment report, and review conclusions. In view of the above, operating permits issued by the EPB are all based on the content (emission factors included) approved by the EPA’s Environmental Impact Assessment Committee. In addition, the calculation of air pollutant emissions inventory is also based on the Administrative Measures for the Reporting of Air Pollutant Emissions Inventory of Stationary Pollution Sources at Public or Private Premises. The reporting for the sixth naphtha cracker plant also followed the above regulations.
(2) The calculation of the total VOC emissions of the sixth naphtha cracker plant was checked. It confirmed that the EIA of the sixth naphtha cracker plant calculated emissions from 8 pollution sources only, including channels of emissions, combustion towers, ships and vessels, equipment components, loading operations and facilities, wastewater treatment units, oil-water separators, and organic liquid storage tanks. The 2011 total emissions reported by the sixth naphtha cracker plant amounted to 2,339 metric tons. However, the total emissions from the 8 sources calculated and verified by the EPB amounted to 2,606 tons. Moreover, the EPB also calculated emissions from 4 sources not covered by the EIA, including paints and coatings, cooling towers, storage tank cleaning activities and maintenance, repair and overhaul (subtotaling 1,133 tons). In total, emissions from the 12 sources amounted to 3,739 tons, among which abnormal emissions and emissions during production downtime after the county government ordered a suspension of work on May 12, 2011 and when repairs and maintenance requested by Industrial Development Bureau, Ministry of Economic Affairs were performed in different phases in different zones were not included
(3) According to the “Taiwan Emissions Database” (version TEDS7.1) published online by the EPA in January 2011, the amount of NMHC emissions for the petroleum refining industry was 9,773 metric tons. However, according to a newer version of the database (TEDS8.0) published in August 2012, the amount of NMHC emissions of the petroleum refining industry was reduced to 124 tons, which is different from the calculation by the EPB based on the Air Pollution Control Act.
(4) Regarding Resolution No.4 of the 219th EIA meeting, instead of being deleted, VOC emissions from the 5 sources and their respective methods of checking and verification should be included.