TO: Mon Valley Clean Air Coalition. Let me propose that the
MVCAC submit a response to the
proposed Acid Rain permit licensing for the Longview power plant, per the
instructions at the bottom
of this message. If we do, there are two issues, (1)
what issues(s) should we raise and (2) should we
request a public meeting be held. I vote Yes on the first
and maybe on the second.
Please consider the draft comments immediately below, and provide feedback
a.s.a.p. Duane
1. Longview has not accurately represented 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. It may well be premature to proceed with the licensing
process.
2. 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, degasses from coal piles, and other gases that
contribute to global climate change. The US-EPA has recently come to
appreciate these considerations and ample evidence is at hand to justify the
consideration of these factors in the acid rain permitting process at this
time.
3. 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. All these are within a 15
mile radius of the power plant, and they are downwind of the plant when
considering the direction of the prevailing winds in this region.
4. 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 generate 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).
5. 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 to 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.
===========================================================
Thursday,
November 6, 2008 @ 3:31
PM
===========================================================
NOTICE OF COMMENT PERIOD FOR DRAFT/PROPOSED ACID RAIN
PERMITUnder 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/daqThe
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.