I support the concept. Attached please find some materials I prepared for the original permit application in 2005. One is my comments on a "fact" sheet circulated by Wellington at the time. A second is a chart illustrating the emissions levels. The third is the comment letter I submitted on the air permit. Feel free to use any that you deem appropriate, although a significant re-write is needed for some of the permit comments.
It is my understanding that a few of the comments I submitted on the original air permit were addressed in the final permit, and several other sections (e.g., mercury emissions rules) clearly need to be updated, as the EPA Clean Air Mercury Rule was overturned and a new mercury rule is to take effect early next year.
In addition, the statements on greenhouse gas emissions need to be given a complete re-write because the Supreme Court has since ruled that greenhouse gases are subject to EPA regulation, and EPA has determined that greenhouse gases constitute a threat to human health (2009 endangerment finding).
I also recommend that we request a significant extension of the comment period, as a simple renewal is not appropriate and a thorough revision of the air permit should be required, including a new BACT analysis. The reason that permits expire after five years is because Congress recognized that new pollution-control technology would make old permits "stale", hence new analyses are required to determine whether the old permit limits are appropriate. Since this plant has not yet started construction, an extension is a direct contradiction of the intent of the Clean Air Act that new BACT analyses be required.
Jim Kotcon
Paula Hunt pjhunt@xemaps.com 12/2/2010 6:22 PM >>>
I second the motion.
- paula
................................................................................ At 12/2/2010 02:34 PM, Duane wrote:
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It is herewith proposed that MVCAC submit testimony in opposition to the 5-year extension of the permit for the Wellington gob burning power plant in Fayette County, PA, just a few miles north of Morgantown. Please let me know if you have comments. . . . . . . . Duane Nichols, MVCAC Spokesperson.
Public Hearing on Plan to Construct Waste Coal-Fired Power Plant in Greene County
On the evening of December 7th the Pennsylvania Department of Environmental Protection will hold a public meeting and hear citizen testimony on Wellington Development LLC's proposal to build a 525 megawatt waste-coal-fired power plant in Nemacolin, Greene County, PA. If constructed, this facility would serve as a massive new source of pollution for Greene County and our region as a whole, including the Pittsburgh metropolitan area, Shenandoah National Park, the James River Face Wilderness Area, Dolly Sods, and Otter Creek Wilderness area.
Wellington first received a permit to build the facility in 2005. (Several years ago GASP joined the Sierra Club, the National Parks Conservation Association, and the Chesapeake Bay Foundation in an ultimately unsuccessful legal effort to invalidate the 2005 permit). Five years later the plant still has not been constructed. Wellington is now seeking a 5-year extension on their construction permit. Our region is already out of attainment for fine particulates and ozone. If built this project would impose an additional air pollution burden on our region for decades to come.
The PADEP hearing is scheduled for December 7th at
United Mine Workers Hall
92 Pershing Boulevard
Nemacolin PA, 15351 (map)
An informational meeting will start at 6:00 p.m., public testimony will start at 7:00 p.m.
Those wishing to present oral testimony during the hearing should contact Community Relations Coordinator Katherine Gresh, at (412) 442-4000, before December 7, 2010 to register. Commentators should provide three written copies of their remarks to aid in transcription. Each commenter's oral testimony shall be limited to 10 minutes.
More information on the project is available in the http://r20.rs6.net/tn.jsp?llr=izlefwcab&et=1104012270817&s=244&e=001fABDckgnBOkfvKtImc7qKiYjEZXmkdfsmsSPaXPpotnzU7LbvblhCIiaHgL6-5MvBKC-a1TufsRp7pDEDywhkjFWH2EDS4kEZRFDcCxfjWYmmCDft9H3w-QaEdhK7je3yLYA9QUWLdEONJ4lVMGCBzOC2fMPukOXn_oiv9TdPSs=Pennsylvania Bulletin (search for Wellington) _______________________________________________ MVCAC mailing list MVCAC@cheat.org http://cheat.org/mailman/listinfo/mvcac
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James Kotcon