I was unable to open the Draft Permit and Evaluation at the DEP website (go to www.wvdep.org and click on offices, then air quality, then public notices, then NSR, then 2005). It may be a problem with the file, since I could open other permits. You may want to call the staff engineer directly to get more info. This might be a good "case study" for the air training on Sunday. Could someone print out a copy of each and bring it, preferably with a laptop computer? The issue should be "what does Mylan want to do and can they do it cleaner?" What kinds of pollution control are proposed, and are there better technologies? That is a fairly large pollution source to put in next to a school. It would approximately triple the existing emissions from the 3 natural gas fired boilers already there (according to their current operating permit (Title V) available at: http://www.wvdep.org/Docs/8160_R30-06100033%20FMP.pdf Based on the existing permit, the NOx emission rate is around 0.1 lb/MMBTU, which is slightly higher than the BACT of 0.07 lb/MMBTU for a coal-fired plant with Selective Catalytic Reduction (e.g., Longview). Whether a natural gas engine is technically able to meet more stringent NOx standards than a coal-fired plant is a question worth answering. But an additional issue is how those emissions limits are being monitored. In the current permit, the only "monitoring" is to record the amount of natural gas being used, and calculating an estimate of how much NOx is formed. For a source this large, next to a school, a "Continuous Emissions Monitoring System" (CEMS) should be required for all NOx sources.

JBK

P.S. The DEP webpage also lists for comment an air permit for WVU Hospitals for 2 emergency generators. These would also emit NOx at about 3 tpy each.

Dr. James Kotcon Interim Program Leader - Organic Agriculture USDA-CSREES Mailstop 2220, Washington, DC 20250 phone: 202-401-4879 Cell: 304-319-2244 fax: 202-401-4888

for overnight carrier: 800 9th St., SW, Room 3344 Washington, DC 20024

-----Original Message----- From: mvcac-bounces@cheat.org [mailto:mvcac-bounces@cheat.org] On Behalf Of Karen Woodfork Sent: Tuesday, June 14, 2005 11:04 PM To: mvcac@cheat.org Subject: [BULK] - [MVCAC] Mylan's proposed polliution increase

According to my calculations, the amount of increase in particulate matter proposed by Mylan is approximately 8.5% of that proposed by Longview. However, Mylan is in a major population center - literally right next to an elementary school and a residential neighborhood and within a short distance of two hospitals and two nursing homes.

Below is the info on the proposal and how to comment:

--- Notice of Comment Period Department of Environmental Protection

This mailing is to advise the public that we have prepared a draft air quality permit for Mylan Pharmaceuticals Inc. to modify and operate a pharmaceutical manufacturing facility located in Morgantown, WV.

Permit Number: R13-2068

Mylan Pharmaceuticals Inc will increase the potential to discharge these

regulated air pollutants and associated amounts: 27.1 tons per year nitrogen oxide; 53.6 tpy carbon monoxide; 0.17 tpy sulfur dioxide; 2.8 tpy volatile organic compounds; and 41.3 tpy particulate matter. The facility is located in Morgantown, Monongalia County, WV.

Please fax, mail or e-mail any comments on the draft permit to the address below, postmarked on or before June 24, 2005. Comments may include a request for a public hearing. A hearing may be held if DEP finds a significant degree of public interest, or if the hearing would clarify issues.

You can view the draft permit, application, and, if available, a fact sheet, all at no cost, at the office below. Call or e-mail to make an appointment. If you would like a copy of any information, copying and mailing costs may apply. DEP Division of Air Quality 601 57th Street, Southeast Charleston, WV 25304 Contact Jill Harris Phone: (304) 926-0499, ext. 1224 Fax: (304) 926-0478 E-mail: jharris@wvdep.org _______________________________________________ MVCAC mailing list MVCAC@cheat.org http://cheat.org/mailman/listinfo/mvcac