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
DRAFT COMMENTS ON THE LONGVIEW ACID RAIN PERMIT APPLICATIONS.
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.
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=========================================================== 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
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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