Using sophisticated optical modeling, states (and Sierra Club) can pinpoint contributions from individual sources to downwind non-attainment areas. We've done similar modeling and it may even have been our modeling that bolstered Delaware's case for doing this.

Bridget can you work with Josh Berman to export a list of WV coal plants and their contributions to downwind NAAs? I wonder where Pleasants will fall on that list. I also wonder how the recent release of CSAPR 2.5 (or whatever we are calling the latest version) affects EPA's likely response to these petitions.

On Wed, Sep 28, 2016 at 8:30 AM, James Kotcon <jkotcon@wvu.edu> wrote:

I had seen a news item about that petition last month (Deleware argues that the Harrison Power plant contributes to their air quality violations) but had trouble understanding why Deleware could be so specific about one plant that already has low-NOx boilers and SCR.  This news article indicates that Harrison frequently operates without using the SCR, which would dramatically increase NOx emissions and down-wind ozone. 


This could exacerbate the costs of operating Harrison, at a time when it is already under fire for costing more to operate than FE had projected.


Anybody know if this has a bearing on Pleasants?


JBK

From: Nachy Kanfer <nachy.kanfer@sierraclub.org>
Sent: Wednesday, September 28, 2016 7:34:27 AM
To: Bill Price; Bridget Lee; James Kotcon
Subject: how did i miss this??
 



--
Nachy Kanfer
Deputy Director, East
Sierra Club Beyond Coal Campaign
(614) 625-3894