From: "Andrews, Edward S" Edward.S.Andrews@wv.gov
Date: September 13, 2021 at 3:04:10 PM EDT To: Duane Nichols Duane330@aol.com Subject: Longview II Permit Application for CCGT Plan in Monongalia County, WV
Mr. Nichols:
This email is a follow-up response to your comments made on January 13, 2020 regarding Longview Power II, which is now Mountain State Clean Energy LLC (MSCE), proposed construction of two natural gas fired combined cycle combustion turbines next to the existing Longview Power Plant near Maidsville. The following is the agency's response to your comments, which is in blue text.
Comment 1. 1. Inadequate notice and confusing advertisements plague this project. The WV-DEP should hold a public hearing and advertise it widely (WV, PA, MD) as it affects many communities in multiple states.
Response: The notices that MSCE had published in The Dominion Post on December 12, 2019, and on March 12, 2021 meet the required criteria in 45 CSR 13 & 45 CSR 14.
Also, the DAQ had notified the appropriate Federal Land Managers over the nearest Class I Areas to the project (Doddy Sods, James River Face, Otter Creek Wilderness Areas & Shenandoah National Park on February 14, 2020 and April 14, 2021.
Once a preliminary determination regarding this project has been made by the agency, the agency will publish a Class I advertisement in the local newspaper (The Dominion Post ) as required by our permitting rules. Also, the agency is required to provide notice to local governing (e.g. County Commission of Monongalia County) and planning bodies (e.g. Morgantown Monongalia Metropolitan Planning Organization) that has jurisdiction over the location that project will be located within. EPA Regional Administrator and appropriate officials with the PA DEP are required to be notified by the agency once the DAQ has made a preliminary determination regarding this application. The agency takes your suggestion for a public meeting under consideration.
Comment 2. The single advertisement that we have seen was in the Morgantown Dominion Post on December 18th. It is dated in the upper right corner as “Dec. 8” and near the bottom appears this line “Dated this the 13th day of December, 2019.” Hence, this is confusion and unclear what the deadlines are for public comment.
Response: MSCE revised their revised application on March 12, 2021 and published a class I legal ad in The Dominion Post, which should have cleared up any confusion you may have had with the December notice.
Section 8 - Public Review Procedures of 45 CSR 13 (Rule 13) and Section 17 - Public Review Procedures of 45 CSR 14 will be followed for this permit application (Rule 14). Section 8.2. of Rule 13 requires the DAQ to continue accepting comments as long as the application is on our list. NSR Permit Applications (wv.gov)
The ad you notice in the December 12, 2019 edition of the Dominion Post and the ad in the March 12, 2021 edition of the Dominion Post are requirements of Notice level A of Section 8.3. of Rule 13 and Section 17.1 of Rule 14. Once the DAQ makes a preliminary determination on this application, the DAQ will publish a legal ad allowing the public to make comments on our finding and recommendations (e.g., preliminary determination and draft permit) for 30 day comment period in accordance with Section 8.4. of Rule 13 and Section 17.4. of Rule 14.
Comment 3. There are nine (9) PSD pollutants listed, making this a major polluter to add to the existing large scale power plants right here in northern Monongalia County.
Response: Applicants seeking to obtain an air permit from this office must disclose the pollutants and amounts to be released from the facility in their notice to the public. MSCE satisfied this requirement in our rule.
Comment 4. The estimated Hazardous Air Pollutants (HAPS) at 9.96 tons per year are almost certainly underestimated, given start-ups, excursions and other upsets. Over two (2) tons of toluene per year is excessive. This will add to the high level of HAPS from the exhausts of coal trucks on the Ft. Martin Hill (300 trucks per day).
Response: Excursions or upsets are not permitted in our permits. MSCE did account for start-ups and shutdowns in their emission estimates. In the revised March 2021 application, the potential to emit HAPs from the project is 23.3 tons per year. The project site is located next to Longview Power and under common control. Thus, the HAPs from both sites are required to be aggregated for applicability purposes to determine if the site is a major source of HAPs. The HAP potential from Longview Power is 15.87 tpy, which makes the total of both sites a potential to emit 39.19 tons per year of HAPs. Therefore, the project is classified as a Major Source of HAPs.
Comment 5. The emissions given must be considered when added to the existing emissions in that area as we are already overwhelmed with coal fired power plant associated pollutants from the Longview I and the Ft. Martin power plants. Longview is already paying annual assessments for polluting the atmosphere.
Response: In this application, MSCE has been required to conduct cumulative analysis for NOx and PM to ensure that the proposed emission units don't cause or contribute to a predicted exceedance of the National Ambient Air Quality Standard (NAAAS) and PSD increment levels for Class II areas (e.g., Monongalia County). A list of these background sources (off site inventory) can be found in Table 7-6 of the application, which includes the emission units at Longview Power and Fort Martin Power Stations.
Comment 6. The heat rejected and air emissions from three (3) power plants creates unacceptable conditions for the Ft. Martin community as well as Maidsville, Star City, Bakers Ridge, Stewartstown (all in WV) plus Pt. Marion, Bobtown, Garards Fort, and Greensboro (in PA). Clouds of vapors, pockets of pollution and streams of emissions are present, some seen and some unseen. Less than 40 % of the heat energy going into these plants becomes electricity, so over 60% is rejected to become atmospheric heat or water vapor. Condensation results in the raining down of pollutants which collect in yards, on homes and in the air for residents to breathe.
Response: MSCE has proposed that the DAQ consider two different manufacturers of the combustion turbine in this application (General Electric and Mitsubishi Hitachi Power Systems). Of the proposed model units in this application, both of these manufacturers claim that their units have an efficiency of greater than 64% a net combined-cycle bases. 64% of the energy consumed by the units is transferred into electricity and transmitted to the power lines leaving the plant. https://www.ge.com/gas-power/products/gas-turbines/7ha https://power.mhi.com/products/gasturbines/lineup/m501j
Comment 7. The deep valleys of the Monongahela River, Dunkard Creek and Cheat River are the primary danger areas were pollutants accumulate, and during inversions become concentrated and highly dangerous to the residents. Modeling will demonstrate this for steady state conditions, but these conditions will be extreme during power plant start-ups, excursions and other upsets.
Response: MSCE has modeled emissions from cold, hot and warm startup event and shutdown events as continuously events over a five year ( 2014 through 2018) period as a demonstration to the DAQ that start-up and shutdown events from their proposed units do not pose a issue with the air quality in the local area (Monongalia County) with regards to maintaining the attainment status for the NAAQS and PSD increment levels.
Comment 8. Continuous or intermittent emission monitoring on a frequent basis is highly needed if this plant is to go forward, not just for this plant but monitoring with alarms to detected emissions from any and all three of these plants, including the emission from the road(s) and coal handling operations in the area.
Response: MSCE is required in this application to demonstrate an analysis of the ambient air quality in the local area of the pollutants that the proposed source could affect. If not enough data is available then the source is required to collect additional data to adequately complete this analysis of the ambient air in the local area. Our permitting rule does not require additional monitoring once a satisfactory analysis of the ambient air quality has been made by the applicant.
Actual NOx emissions from the combustion turbines are required to be monitored on a continuous basis by the source.
The WV DEP and PA DEP operate, record and report ambient concentrations of pollutants such as ozone, SO2, NOx, and PM2.5 from four monitoring sites within 30 km of the proposed site. EPA uses this data to forecast and report Air Quality (Air Quality Index - AQI). Air Quality Index (AQI) | AirNow.gov Changes to any of our monitoring site locations would require EPA approval. The selection of a monitoring site is not an activity that falls under the roll permitting section of the DAQ.
Comment 9. The carbon dioxide and methane emission will be excessive and the State of West Virginia is oblivious to these. Have you no sense of right and wrong, considering that you are being paid as public servants. The facts that the Governor and the Director of DEP as political actors are only concerned about serving industry, does not relieve the staff and technical employees from performing rational and complete duties to protect the people of WV, PA, MD and the US from hazards, unhealthy conditions, and global threats.
Response: Under 45 CSR 14, MSCE application represents a significant increase and net increase of one or more NSR pollutants ( CO, NOx, VOC, Ozone, PM, PM10, PM2.5) and a significant increase in one of the six greenhouse gases (CO2). Thus, MSCE is required to prepare and submit a Best Available Control Technology analysis for CO2 emissions from the facility.
Thank-you for your remarks that pertain to Permit Application R14-0038. Should you have any additional questions about this application, please contact me.
Sincerely, Edward Andrews, P.E., Engineer WVDEP/Division of Air Quality 304-926-0499 Ext 41244 601 57th Street, SE Charleston, WV 20304
On Tue, Jan 21, 2020 at 11:02 AM Andrews, Edward S Edward.S.Andrews@wv.gov wrote: Mr. Nichols,
Thank-you for your comments. The DAQ will response to your comments once the application is deem complete. Currently, the status of this application is incomplete.
Should you have any questions, please contact me.
Edward S. Andrews, P.E.
Engineer
West Virginia Department of Environmental Protection
Division of Air Quality
601 57th Street, SE
Charleston, WV 25304
304.926.0499 ext. 1214
From: Duane Nichols duane330@aol.com Sent: Monday, January 13, 2020 3:48 PM To: Andrews, Edward S Edward.S.Andrews@wv.gov Subject: [External] Longview II Permit Application for CCGT Plan in Monongalia County, WV
CAUTION: External email. Do not click links or open attachments unless you verify sender.
ATTN: Edward S. Andrews
WV Dept. of Env. Protection
Division of Air Quality
601 57th Street, SE
Charleston, WV 25304
RE: Longview II Permit Application for CCGT 1200 MW, Maidsville, WV
Inadequate notice and confusing advertisements plague this project. The WV-DEP should hold a public hearing and advertise it widely (WV, PA, MD) as it affects many communities in multiple states.The single advertisement that we have seen was in the Morgantown Dominion Post on December 18th. It is dated in the upper right corner as “Dec. 8” and near the bottom appears this line “Dated this the 13th day of December, 2019.” Hence, this is confusion and unclear what the deadlines are for public comment.There are nine (9) PSD pollutants listed, making this a major polluter to add to the existing large scale power plants right here in northern Monongalia County.The estimated Hazardous Air Pollutants (HAPS) at 9.96 tons per year are almost certainly under estimated, given start-ups, excursions and other upsets. Over two (2) tons of toluene per year is excessive. This will add to the high level of HAPS from the exhausts of coal trucks on the Ft. Martin Hill (300 trucks per day).The emissions given must be considered when added to the existing emissions in that area as we are already overwhelmed with coal fired power plant associated pollutants from the Longview I and the Ft. Martin power plants. Longview is already paying annual assessments for polluting the atmosphere.The heat rejected and air emissions from three (3) power plants creates unacceptable conditions for the Ft. Martin community as well as Maidsville, Star City, Bakers Ridge, Stewartstown (all in WV) plus Pt. Marion, Bobtown, Garards Fort, and Greensboro (in PA). Clouds of vapors, pockets of pollution and streams of emissions are present, some seen and some unseen. Less than 40 % of the heat energy going into these plants becomes electricity, so over 60% is rejected to become atmospheric heat or water vapor. Condensation results in the raining down of pollutants which collect in yards, on homes and in the air for residents to breathe.The deep valleys of the Monongahela River, Dunkard Creek and Cheat River are the primary danger areas were pollutants accumulate, and during inversions become concentrated and highly dangerous to the residents. Modeling will demonstrate this for steady state conditions, but these conditions will be extreme during power plant start-ups, excursions and other upsets.Continuous or intermittent emission monitoring on a frequent basis is highly needed if this plant is to go forward, not just for this plant but monitoring with alarms to detected emissions from any and all three of these plants, including the emission from the road(s) and coal handling operations in the area.The carbon dioxide and methane emission will be excessive and the State of West Virginia is oblivious to these. Have you no sense of right and wrong, considering that you are being paid as public servants. The facts that the Governor and the Director of DEP as political actors are only concerned about serving industry, does not relieve the staff and technical employees from performing rational and complete duties to protect the people of WV, PA, MD and the US from hazards, unhealthy conditions, and global threats.Duane Nichols, Coordinator
Mon Valley Clean Air Coalition
330 Dream Catcher Circle
Morgantown, WV 26508
304-216-5535, Nichols330@gmail.com, duane330@aol.com