MON VALLEY CLEAN AIR COALITION P. O. Box 4679, Morgantown, WV 26504
November 22, 2008
Attn: John A. Benedict, Director Division of Air Quality WV Department of Environmental Quality 601 57th Street SE Charleston, WV 25304
RE: Proposed Phase II Acid Rain Permit, R33-56671-2013-1, Longview Power LLC
A number of substantial issues have been identified which need to be taken into account for the proposed Phase II Acid Rain Permit for the Longview coal-fired power plant under construction at Maidsville, Monongalia County, West Virginia. Notice of the comment period is dated November 6, 2008 with comments required in duplicate, sent to the Director of the WV Division of Air Quality. This letter complies with these directions. A copy of this Notice is the Attachment to this Letter. Also, a copy of this letter is being sent to the Regional Administrator of the Region 3 Office of the Environmental Protection Agency in Philadelphia, PA.
Our comments are numbered for ease of identification and consideration:
1. Longview has not accurately represented or recently updated the status of the proposed power plant. Schedules are not provided to accurately represent the status of the construction work, the environmental permitting, and the financing for the power plant. Schedules should be solicited from Longview by the WV-DAQ and made public to determine the status of the construction, environmental permitting and availability of secure financing. It appears at this time that it would be premature to proceed with the licensing process.
2. The existing Longview air pollution permit at Section 20, pp. 9 and 10, addresses where the proposed acid rain allowances should come from. These conditions and specifications should be incorporated into any Longview Phase II Acid Rain Permit that is subsequently issued.
3. The proposed power plant will be releasing uncontrolled greenhouse gases, gases that should be considered for documentation, measurement and/or control for this and other large generators of carbon dioxide, carbon monoxide, degas and gob gas from coal piles, and other gases that contribute to global climate change. The US-EPA has recently come to realize these considerations and ample evidence is at hand to justify the consideration of these factors in the acid rain permitting process at this time.
4. Local nature preserves within only a few miles of the proposed power plant are in danger of serious damage if continued emissions of acid gases, which result in acid rain, take place. The protections offered to date are not judged to be adequate for protection of these nature preserves. Regionally we have the Dolly Sods and Otter Creek reserves as Class 1 federally protected regions. In addition we have the Coopers Rock State Forest that contains threatened forest species as well as the Cheat three tooth snail. The Snake Hill Wildlife Management Area contains undergrowth and new saplings that are in need of protection. The West Virginia Botanical Garden, the WVU Earl Core Arboretum, and the Forks of Cheat Forest Nature Preserve are all formal documented nature preserves that deserve consideration and protection from acid rain and other possible harm. These are within a 20 mile radius of the power plant, and they are downwind of the plant when considering the direction of the prevailing winds in this region.
5. The Longview power plant is sited for northcentral Monongalia County in northcentral West Virginia. This Monongalia County has been determined to have an unusually high level of fine particular matter in the air. The US-EPA has underway the decision process to determine by mid-December 2008, why Monongalia County should not be place in the “non-attainment” status for particulates smaller than 2.5 microns, i.e. “PM-2.5”. Given that fine particulate matter in this size range is generated predominantly by sulfur oxides and to some extent the nitrogen oxides where the primary sources are fossil fuel combustion, i.e. coal-fired power plants, it stands to reason that new emissions need to be limited substantially to preserve the quality of the ambient air for all the citizens of the county and region. And, given that acid rain is generated by these same precursors, viz. sulfur oxides and nitrogen oxides. Therefore, the underlying problems are the same and consideration of one issue (non-attainment) is interrelated with the other issue (acid rain).
6. Due to the high fine particulate levels reported for Monongahela County in West Virginia, as reflected by the “non-attainment” status considerations now prevailing, any Longview Acid Rain allowances obtained should come from this same locality, i.e. Monongahela County, to protect the said locality to the extent possible.
7. Extremely high levels of sulfates in the local streams has resulted in the curtailment of industrial activities in the region of Monongalia County and southwestern Pennsylvania. These same problems are impacting the water supplies for over 350,000 people in this same region. Sulfate ion concentrations as high as 400 parts per million are being monitored in the Monongahela River and some of the tributaries are showing higher concentrations. Already mitigating actions are being called for to reduce the acidic effluents and protect the public water supplies and industrial water sources. The emission of acid gases in the presence of the large steam plumes from the Longview power plant will adversely impact the local streams with increases in sulfate ion and other substances that contribute the total dissolved solids (TDS) content of the streams here. The TDS levels being monitored in the Monongahela River at the USGS station at Elizabeth (PA), downstream of the proposed Longview emissions, has been showing electrical conductivity levels (a surrogate for TDS) more than twice as high as had otherwise been observed over the past 35 years.
8. The Hatsfield Ferry coal-fired power plant is located within a few miles downstream of the Longview power plant and has experienced violations of its air quality permit as a result of the high total dissolved solids (TDS) level described in Issue 7 above. Recent chemical analysis results from the Department of Environmental Protection in Pennsylvania have demonstrated that the primary constituent making up the high TDS levels is sulfate ion. The dissolved solids cannot be removed via filtration and are present in the cooling water being evaporated by both the Ft. Martin power plant (in West Virginia) and the Hatsfield Ferry power plant (in Pennsylvania), both within view of the Longview power plant site. The TDS levels in this cooling water have been at 500 parts per million or higher in West Virginia and somewhat higher than that in Pennsylvania. These solids are thus contributing to the “particulate matter” or PM emissions now affecting the locality of these plants, the wider region and perhaps the other eastern States. The WV DEP, the Department of Environmental Protection and other authorities in Pennsylvania, and the US EPA have a responsibility to resolve this major problem in the Monongahela River valley before any new permits are issued.
Should any further explanation be needed or documentation be required, then a Public Hearing should be held which explicitly calls for these criteria to be addressed. We deplore the fact that the West Virginia Department of Environmental Protection has not tried to provide factual information or educational matter to the public so as to help address the issues under consideration. Nor has this agency shown any initiative to protect the public from the impacts of air and water pollution in the Mononghela River valley.
Submitted by:
William Wonderlin, Convenor MonValley Clean Air Coalition P. O. Box 4679 Morgantown, WV 26504
Cc: Donald S. Welsh, Regional Administrator US EPA Mid-Atlantic Region (Region 3) 1650 Arch Street (3PM52) Philadelphia, PA 19103-2029
ATTACHMENT =========================================================== Thursday, November 6, 2008 @ 3:31 PM ===========================================================
NOTICE OF COMMENT PERIOD FOR DRAFT/PROPOSED ACID RAIN PERMIT
Under Phase II of the Acid Rain Program (40 CFR 72 and 45CSR33), the West Virginia Department of Environmental Protection, Division of Air Quality (DAQ) proposes to approve a Phase II Acid Rain Permit, R33-56671-2013-1, for Unit 001 at Longview Power LLC’s Longview Power facility located near Morgantown, West Virginia.
Longview Power is not eligible to receive sulfur dioxide (SO2) allowance allocations from the U.S. EPA under 40 CFR part 73, but may acquire allowances from other sources. This unit is still obligated to hold SO2 allowances as required under and in accordance with 40 CFR §72.9(c)(1). One allowance authorizes the unit to emit one ton of sulfur dioxide.
The permit does not affect Longview Power’s responsibility to meet all other existing local, state and federal requirements related to SO2 and nitrogen oxide (NOx) emissions.
The Designated Representative for Longview Power is Mr. Charles Huguenard of Longview Power LLC, 306 Dents Run Road, Morgantown, WV 26501.
All written comments submitted by the public and affected state(s) pursuant to this notice must be received by the DAQ within thirty (30) days of the date of publication of this notice. Under the Direct proposed procedures of 40 CFR §72.72(b)(1)(v), if no significant, adverse comments are timely submitted, the proposed permit will be deemed issued on the publication date of this notice or from the date the USEPA receives this draft/proposed permit, whichever is later. Written comments submitted by the USEPA must be received by the DAQ within forty-five (45) days from such date. If significant, adverse comments are timely submitted, the proposed permit will be issued in accordance with 40 CFR §72.72(b)(1)(iv). In the event that the 30th//45th day is a Saturday, Sunday, or legal holiday, the comment period will be extended until 5:00 p.m. on the following regularly scheduled business day.
Copies of the Draft/Proposed Permit may be downloaded from the DAQ's web site at the following address: _http://www.wvdep.org/daq_ (http://www.wvdep.org/daq)
The Draft/Proposed Permit and the Administrative Record, except information protected as confidential, are available for public review at the following location(s) between the hours of 8:00 a.m. to 5:00 p.m.:
WV Department of Environmental Protection Division of Air Quality 601 57th Street, SE Charleston, WV 25304 Contact: Frederick Tipane (304) 926-0499 ext. 1215
OR WV Department of Environmental Protection Division of Air Quality North Central Regional Office 2031 Pleasant Valley Road, Suite #1 Fairmont, WV 26554-9295 (304) 368-3910
Send comments, and/or requests for a public hearing to John A. Benedict, Director, Division of Air Quality, at the above Charleston address. Submit all comments in duplicate and identify the permit to which the comments apply. The submission shall include the commenter’s name and address, the commenter’s interest in this matter and the affiliation, if any, the commenter has to the owner or operator of the unit(s) covered by the permit. All relevant, timely comments will be considered except for those pertaining to any standard requirement under 40 CFR §72.9 and issues not related to the permit, such as the environmental effects of acid rain or permit issuance procedures or actions on other permit applications not relevant to the issuance or denial of the permit. Any person who requests a public hearing must state the issues proposed to be raised in the hearing. If the DAQ finds that a hearing will contribute to the decision making process by clarifying significant issues affecting the draft/proposed permit, a hearing will be announced.
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